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Home My WebLink About01-0952COMMERCE BANK/HARRISBURG, : Plaintiff DENNIS E. SHOCKLEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKETNO. O/- NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff(s). You may lose money or property or other rights important to you. 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 (717) 249-3166 (800) 990-9108 COMMERCE BANK/HARRISBURG, : Plaintiff Vo DENNIS E. SHOCKLEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTA. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990~9108 COMMERCE BANK/HARRISBURG, : Plaintiff Yo DENNIS E. SHOCKLEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. o/-~5-~L ~ COMPLAINT AND NOW, Plaintiff, COMMERCE BANK/HARRISBURG, N.A., through its counsel, Metre, Evans and Woodside, brings this Complaint before the Court, in support of which it avers as follows: 1. Plaintiff is Commerce Bank/Harrisburg, N.A. (hereinafter "Commerce Bank"), a national banking association with an office at 100 Senate Avenue, Camp Hill, Pennsylvania 17001-8599. 2. Defendant Dennis E. Shockley is an adult individual who resides at 923 Greenbriar Road, York, Pennsylvania 17404. 3. On March 31, 1999, 4 NU Marketing, Inc. (hereinafter "NU Marketing"), upon information and belief a Pennsylvania business corporation with an office at 1600 Pennsylvania Avenue, Cyber Center, York, Pennsylvania 17404, executed and delivered to Commerce Bank a promissory note (hereinafter "Note") evidencing its obligation to Commerce Bank under a Business Loan Agreement dated March 31, 1999 (hereinafter "Agreement") pursuant to which NU Marketing obtained a revolving line of credit from Commerce Bank. True and correct copies of the Note and the Agreement are attached hereto, respectively, at Exhibits "A" and "B." the Note. Commerce Bank advance the sum of $125,000 to NU Marketing under 5. Pursuant to the Note, NU Marketing covenanted and agreed that it would pay the indebtedness as provided in the Note and that the whole principal sum and interest would become due at the option of Commerce Bank in the event that it failed to keep, observe or perform any of the covenants, conditions or agreements contained therein. 6. Specifically, pursuant to the Note, "[u]pon default, Lender may, after giving such notices as required by applicable law, declare the entire unpaid principal balance on this Note and all accrued unpaid interest immediately due, and then Borrower will pay that amount." (See Exhibit "A" under heading "Lender's Rights.") 2 7. NU Marketing has defaulted in the performance of its obligations under the Note by failing to pay, inter alia, the monthly installments of principal and interest due as required under the Note. 8. By notice dated September 28, 2000, Commerce Bank provided NU Marketing with written notice of its default. A true and correct copy of the written notice is attached hereto at Exhibit "C" and incorporated herein by reference. 9. NU Marketing has failed and refused to cure its default under the Note. 10. On the same date as the Note and Agreement (i.e., March 31, 1999), Defendant Dennis E. Shockley executed a Commercial Guaranty (hereinafter "Guaranty") pursuant to which he "absolutely and unconditionally guarantees and promises to pay to Commerce Bank * * * 100% of the Indebtedness * * * of 4 NU Marketing, Inc. * * * on the terms and conditions set forth in this Guaranty." A true and correct copy of the Guaranty is attached hereto at Exhibit "D" and incorporated herein by reference. 11. Specifically, pursuant to the Guaranty, uarantor ~ntends to guarantee at all times the performance and prompt payment when due, whether at maturity or earlier by reason of acceleration or otherwise, of all Indebtedness within the limits set forth in the preceding section of this Guaranty. This Guaranty covers a revolving line of credit and Guarantor understands and agrees that this Guarantee shall be open and continuous until the line of credit is terminated and the Indebtedness is paid in full, as provided below." (See Exhibit "D" under heading "Nature of Guaranty.") 12. By notice dated December 8, 2000, Commerce Bank provided Defendant Dennis E. Shockley with official notice that the Note was in default and that Commerce Bank, under the terms and conditions of the Guaranty, was "making a demand upon [him] for repayment of the loan obligation." A true and correct copy of the official notice is attached hereto at Exhibit "E" and incorporated herein by reference. 13. Commerce Bank advised the Defendant that he had "ten days from the date of [the notice] to contact [Commerce Bank] to discuss the possible terms of loan repayment." (See Exhibit "E.") 14. Defendant Dennis E. Shocldey received notice that the Note was in default on December 9, 2000. True and correct copies of the U.S. Postal Service Certified Mail Receipt (Article No. 7099 3400 0001 4127 7781) and PS Form 3811 evidencing receipt are attached hereto at Exhibit "F." 4 15. Defendant Dennis E. Shockley has failed and refused to contact Commerce Bank "in order to discuss the possible terms of the loan repayment" or otherwise act in accordance with his duties under the Guaranty by curing the default of NU Marketing under the Note. 16. Commerce Bank has called the Note and declares that the unpaid principal balance, together with accrued interest, attorney's fees and costs as provided therein to be immediately due and payable by Defendant Dennis E. Shockley pursuant to the terms and conditions of the Guaranty. 17. The following amounts are currently due and owing Commerce Bank on the Note: Unpaid Principal Balance Interest Accrued and Unpaid as of February 13, 2001 ($26.29 per diem) (To be further calculated at the time of complete payment or collection) Late Fees as of February 13, 2001 (To be further calculated at the time of complete payment or collection) Attorneys' Fees and costs of suit TOTAL: $90,152.37 $6,541.06 $4,727.90 To be determined $101,421.33 (As of February 13, 2001) 5 WHEREFORE, Plaintiff respectfully requests that judgment be entered in its favor and against Defendant Dennis E. Shockley in the amount of $101,421.33 plus interest thereon of $26.29 per diem plus attorneys' fees, costs and other charges as provided in the Note and Guaranty, and awarding Commerce Bank such other relief as is just under the circumstances. Respectfully submitted, METTE, EVANS & WOODSIDE ~P. Beneventano, Esquire Sup. Ct. I.D. #43107 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 Attorneys for Plaintiff Commerce Bank/Harrisburg, N.A. Date: Exhibit A PROMISSORY Principal Amount: $125,000.00 initial Rate: 10.000% Date of Note: March 31, 1999~ 03-31-1999 PROMISSORY NOTE Page 2 Loan No 2805450 (ConUnued) (SEAL) ( Corporate Se.l ) Exhibit B BUSINESS LOAN AGREEmeNT 03'31-1999 Loan No 2805450 , BUSINESS LOAN AGREEMENT (Continued) Page 03-31-1999 ~" BUSINESS LOAN AGREEI~NT Loan No 280~450 D~i. F- ~ 1oe.ooo~ of slas,ooe.oe 03-31-1999 BUSINESS LOAN AGREEMENT Loan No 28054~) (Con#nued) Page o3-31-1999 '~ BUSINESS LOAN AGRE~f~=2NT Loan Mo 2805450 ~ .~ _~ . . , (~n~) Page 5 Exhibit C Commerce ,Bank,. September 28, 2000 4 NU Marketing, Inc. Account No. 280540 4 NU Marketing, Inc. 140 RooseYelt Ave., Suite 209 York, PA 17404 Dear Sirs, This loan is past due for payments for July 30, 2000, August 30, 2000. You were sent timely notice of these payments. The bank is hereby demanding payment in full on this loan by 3:00 p.m. on October 10, 2000. This is your final notice. Through September 27, 2000, the indebtedness that you owe the bank is $92,382.08 plus any attorneys' fees and other costs of collection. Such $92,832.08 is computed as follows: Principal through 9/27/00 Interest through 9/27/00 Late fees th.'ough 9/27/00 Total $90,152.37 2,591.89 87.82 $92,832.08 Interest continues to accrue currently on such indebtedness on a per annum basis at Commerce Bank/Harrisburg, NA Prime Rate plus one and one-half percent per annum, on a floatin!.~ basis. Currently this equals eleven and one-half (11.50%) percent. The current per diem accrual is $28.80. Any attorneys' fees and collection costs will also accrue. Commerce Bank, NA. P.O. Box 8599 l O0 Senate Avenue Camp Hi;I, Pennsylvania 1700r-8599 You should contact me in person or by telephone at (717) 975-5630 to determine the exact payoff amount. If the indebtedness that you owe the bank is not paid in full on or before October 10, 2000 we will instruct our attorneys to proceed immediately against you and your property in order to collect the indebtedness. Such action will include among other things the entry of judgment by confession against you. Very truly yours, [~d C Amsden Vice President/Asset Quality DCA CC: G. Beneventano, Esq. Jerome Kubicki Stephanie Kubicki Dennis Shockley Marry Trimmer Brent Carman Ro~er Guttridge Via Regular U.S. Mail Via Certified Mail, return receipt requested Exhibit Loan No 2805450 COMMERCIAL GUARANTY Page 2 (Continual) COMMERCIAL GUARA~,Y Page 3 03-31-1999 ~ (Continued) Loan No Exhibit E GuY P. BENEVENTANO ~fB??B, B'VA.~8' ,J WOODf811;*e December 8, 2000 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED Dennis E. Shockley 923 Greenbriar Road York, PA 17404 Marry L. Trimmer J 2970 Persimmon Drive York, PA 17404 Stephanie A. Kubicki 2642 Wedgewood Way York PA 17404 Brent L. Cai,lan 2195 Ridge View Drive Dallastown,'PA 17313 Jerome E.-Kubicki 2462 Wedgewood Way York, PA 17404 4 NU Marketing, Inc.~Commerce Ba'~k Business Loan Agreement 633.906 Gentlemen and Ms. Kubicki: I write to you on behalf of my client, Commerce Bank, in connection with the above-identified Business Loan Agreement. On March 31, 1999, 4 NU Marketing, Inc. (hereinafter "NU Marketing"), executed and delivered to Commerce Bank a Promissory Note evidencing its obligation to Commerce Bank under a commercial loan in the principal amount of $125,000, together with interest and other charges. Commerce Bank advanced the full amount of the $125,000 to NU Marketing under the Note. Pursuant to the Business Loan Agreement, loan guarantees were required from the four of you prior to disbursement of the loan proceeds. Each of you signed a commercial guaranty instrument obligating you to pay to Commerce Bank 100% of the indebtedness of NU Marketing in the event that it defaulted on its loan obligation to Commerce Bank. Exhibit F · Complete items 1.2. ~nd 3. AJso complete ~tem 4 if Restncted Delivery is desired. · Pdnt your name and a(~dress on the reverse so that we can return the care to you. · Attach this car~ to the oack of the mailpiece. '~or on the front if space permits. DENNIS E. SItOCy~E'y 923 GREENBR~_~,R ROAD YORK, PA 17404 2. Article Number (COpy from service/abe/) 7099 3400 000] 4.127 7781 PS Form 3811 July 1999 A. Receivedby(P/easepr~tC/~r/y) 8. DateofDe~rve~y C. Si nature E:3 rnsur~_ Mail [] C.O.D. DENNIS o"- I .............................................. FEB-14-2001 1~:~ COMMERCE BONK 717 9?5 0~81 ~.0~70~ I, David C. Amsden, state that I hold the title of Vice President/Asset Quality at Commerce Bank/Harrisburg, N.A., the Plaintiff in the above-captioned action, that I am authorized to make this Verification on its behalf, and that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, .i.m~e~ien:and~belief. I understand that my statements are made subject to the penalties of 18 Pa.C.S~L §4904 relating to unsworn falsification to authorities. Date: COMMERCE BANK/HARRISBURG, N~. David C. Anasden Vice President/Asset Q~mlity TOTAL P.03 SHERIFF'S RETURN - 'CASE NO: 2001-00952 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COMMERCE BANK/HARRISBURG VS SHOCKLEY DENNIS OUT OF COUNTY R. Thomas Kline duly sworn according to and inquiry for the within named DEFENDANT SHOCKLEY DENNIS E but was unable to locate Him deputized the sheriff of YORK , Sheriff or Deputy Sheriff who being law, says, that he made a diligent search and in his bailiwick. County, serve the within COMPLAINT & NOTICE to wit: He therefore Pennsylvania, to On March 6th 2001 this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 DEP. YORK COUNTY 24.14 .00 61.14 03/06/2001 METTE, EVANS Thomas Kline Sheriff of Cumberland County & WOODSIDE Sworn and subscribed to before me this ~ day of ~ COUNTY OF YORK OFFICE OF THE SHERIFF 28 EAST MARKET ST·, YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 1, PLAINTIFF/S/ Commerce Bank/Harrisburg, N.A. 3. DEFENDANT/S/ Dennis E. Shockley SERVICE CALL (717) 771-9601 2. COURT NUMBER Civil 4. TYPE OF WRIT OR COMPLAINT Notice & Complaint 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, A3~'ACHED, OR SOLD. SERVE / Dennis E. Shockle¥ 6. ADDRESS (STREET OR RFD WITH SOX NUMBER, APT NO., CITY, BORO, TWR, STATE AND ZIP CODE AT 923 Greenbriar Rd, York, PA 17404 7. INDICATE SERVICE: r't PERSONAL ~ PERSON IN CHARGE ~I~DEPUTIZE ST CLASS MAIL POSTED NOW ? / 1 6 / 0 1 19 __ I, SHERIFF OPZt~:~ CO~1~1~ P~I~o hereby deJ~lJi~e~ne sheriff of v,-,,-'~ COUNTY to exe~[l~i~ re~lil~of~ccording to law. This deputation being m~d~e-at~the request and risk of the plaintiff· 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cumberland n OTREH ADVANCE FEE PAID BY CU~ERLAND COUNTY SHERIFF NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may ~eave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYP~]~JM~.N Dj~ .h ..V ~f~8;nn;~ RN E~olGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED 3401 N. FRONT ST., RO BOX 5950, HARRISBURG, PA 17110'~0950 2/16/01 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice Is to be mailed)· CL1H~ER.[..,~',I~ CO~ SHERIFF SPACE BELOW FOR USE OF THE SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 13. [ acknowledge receipt of the writ SIGNATURE OF AUTHORIZED CLERK 14. Date Received 15. Expiration/Hearing Date or complaint as indicated above./ J. LUDWIG 2/20/01 3/18/01 PERSONAL~/~'~ RES'DEN.~'~ POSTED( ) POE( ) SHERIFF'SOFF( ) OTHER( ) S EEREMARKS 16. HOW SERVED: 17. ~} I hereby cerlify and return a NOT FOUND because~ am unable to ~ocate the individual, company, corporation, etc, named above. (See remarks below.) 18 NAMF,~ND TITLE O,F ND V DUAL SF~I~VED I L ST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Dgte of S~vice 20. Time of Service ' , ,, 21. A3'r~MPTS~,~ I~.~l (l;~ ~,,.~,Tlme M es nt. Date ] ~(~Tim lies Int. Date [i Time Miles Int. Date II Time Miles Int. Date T me I: Miles Int. Date T me Miles i Int, 22· REMARKS: ~"~'~023~" . Advancel00.00 I18.00C°sts 124 . Serv ce Cos s 125../FI4'14126 M eage II 27. Postage 1 22.1428' Sub Total ]129. Pound I] 30.2.0Notary;3 Fee 31, Surcharge ~34. Foreign County Costs 35. Advance Costs 36. Service Costs 37. Notary Ced, 38. M eage/Postage/N.F. 39. Total Costs SO ANSWER. 32. Total Costs ~3. ' ~o~efund~ 24.14 75.86~'~'~ 40, Cost Due or Refund 41. AFFIRM D and sub~",l~.~,l "' ~ r ?~" · I ""=~r~n;_w,,,w~2l)o: MY COMMIS¢ON ~PIRSS , ~ ~ ' 50. I ACK~WLEDGE RECEIPT OF THE'SHERIFF'S ~ETURN SIGNA~RE OF AU~ORiZED I~UING AUTHORt~ ~D TITLE 44. Signature of 47, Dat .45. Signature of York ~' - . 48. Date FOR WILL'[AH H. HOSE ~ I 312/01 46, Signature of Foreign County Shedfl 51. Date Received 1. WHITE - Issuing Authority 2. PINK -Attomey 3. CANARY - Shedf~s Office 4. BLUE - Sheriff's Office COMMERCE BANK/HARRISBURG, : Plaintiff Vo DENNIS E. SHOCKLEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : DOCKET NO. 01-952-Civil PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: PROTHONOTARY PLEASE enter judgment in default in favor of Plaintiff, Commerce Bank/ Harrisburg, N.A., and against Defendant Dennis E. Shockley for failure to plead to the Complaint in this action within the required time. The Complaint contains a Notice to Defend within twenty days from the date of service thereof. Defendant was served with the Complaint on February 28, 2001. Defendant's Answer was due to be filed on or before March 20, 2001. Attached as Exhibit "A" is a copy of Plaintiff's written notice of intention to file Praecipe for Entry of Default Judgment, which I certify was mailed by regular mail to Defendant on March 22, 2001, which is at least ten days prior to the filing of this Praecipe. Please enter judgment against Defendant in the amount of $101,421.33, plus interest thereon at $26.29 per diem, plus attorneys' fees, costs and other charges as demanded in the Complaint. Date: May 4, 2001 Respectfully submitted, METTE, EVANS & WOODSIDE S~upY. P. Beneventano, Esquire Ct. I.D. #43107 f---~401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 Attorneys for Plaintiff Commerce Bank/Harrisburg, N.A. Exhibit A Guy P. ]~ENEVENTANO March 22, 2001 Dennis E. Shocldey 923 Greenbriar Road York, PA 17404 Re: Commerce Bank/Harrisburg, N~A. v. Dennis E. Shockley Cumberland County, C.C.P. No. 01-952-Civ~! Dear Mr. Shocldey: Enclosed please find a Notice of Default sent to you by Commerce Bank/Harrisburg, N.A., in connection with the above-captioned civil action. Very truly yours, GPB:gls Enclosure ce (w/enclosure): Mare Roberts, Esquire 255287 COMMERCE BANK/HARRISBURG, N.A., Plaintiff DENNIS E. SHOCKLEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. 01-952-Civil IMPORTANT NOTICE TO: Dennis E. Shocldey 923 Greenbriar Road York, PA 17404 Date of Notice: March 22, 2001 YOU ARE IN DEFAULT BECAUSE YOU I-LAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAy LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Date: March 22, 2001 METTE, EVANS AND WOODSIDE Beneventano, Esquire 3401 North Front Street P. O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 Attorneys for Plaintiff Commerce Bank/Harrisburg, N.A. COMMERCE BANK/HARRISBURG, PLEAS N.A., PENNSYLVANIA Plaintiff Vo DENNIS E. SHOCKLEY, Defendant IN THE COURT OF COMMON CUMBERLAND COUNTY, CIVIL ACTION - LAW DOCKET NO. 01-952~Civil CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requi[ements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same ~n the United States Mail, Harrisburg, Pennsylvania, First Class Mail, postage prepaid, as follows: Dennis E. Schockley 923 Greenbriar Road York, PA 17404 Marc Roberts, Esquire 149 East Market Street York, PA 17401 Date: May 4, 2001 METTE, EVANS & WOODSIDE //~up. C ~ fi.eDn, e;;3~ t0aTn ° ' E s q uir e 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 Attorneys for Plaintiff Commerce Bank/Harrisburg, N.A. :259647 _1 COMMERCE BANK/HARRISBURG, N.A., Plaintiff DENNIS E. SHOCKLEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW DOCKET NO. 01-952-Civii NOTICE OF ENTRY OF DEFAULT JUDGMENT TO: Dennis E. Shockley YOU ARE HEREBY notified that on ]'~.,,/ '~ ,2001, the following judgment was entered against you in the above~cal~tioned case. Judgment against Defendant in the amount of $101,421.33, plus interest thereon at $26.29 per diem, plus attorneys' fees, costs and other charges as demanded in the Complaint. Prothonotary I hereby certify that the name and address of the proper persons to receive this Notice are: Dennis E. Schocldey 923 Greenbriar Road York, PA 17404 Por este medio se le esta notificando que el , de ,2001, el/la siguiente (orden), (Decreto), (Fallo) ha sido anotado-~n contra suya en el caso mencionado en el epig~afe. FECHA: Protonotagio Certifico que la siguiente direeeion es la del defendido/a segun indieada en el certificado de residencia: Dennis E. Schocldey 923 Greenbriar Road York, PA 17404 Abogado del Demandante