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Home My WebLink About10-4161COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, : DOCKET NO. Plaintiff : V. : CONFESSION OF JUDGMENT AAA CONVENIENCE, INC., DBA r?_ UNI-MART, %? ? Defendant PREVIOUSLY ASSIGNED TT&A cA CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of attorney, the original or a copy of which is attached 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: a. b. C. d. Principal Interest to June 2, 2010 Late Charges Attorneys' Fees TOTAL: $172,333.04 $ 7,195.09 $ 2,113.72 $ 17,952.81 $199,594.66, plus interest, other expenses, fees and costs Respectfully submitted, McNees Wallace & Nurick LLC Date: Junell-,, 2010 S. S ff, Esquire preme Co)drt ID #24848 100 Pine eet, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff ?' 1.7. Sd P oC a?y By: ?Y COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. f , L 6? c W, Plaintiff 7 V. AAA CONVENIENCE, INC., DBA UNI-MART, Defendant CONFESSION OF JUDGMENT PREVIOUSLY ASSIGNED TO: I 0 4 N N COMPLAINT FOR CONFESSION OF JUDGMENT UNDER RULE 2951 -ii 54 1. The Plaintiff, PNC Bank, National Association, is a national banking association organized and existing under the laws of the United States of America with a principal regional office located at 1600 Market Street, 11th Floor, Philadelphia, PA 19103 (the "Plaintiff'). 2. The Defendant, AAA Convenience, Inc., dba Uni-Mart, is a Pennsylvania business corporation with a last known address of 1004 Wesley Drive, Mechanicsburg, PA 17055 (the "Defendant'). 3. The Defendant executed and delivered to the Plaintiff a U.S. Small Business Administration Note dated April 15, 2005, in the original principal amount of Three Hundred Three Thousand Eight Hundred Dollars ($303,800) (the "Note"), a true and correct photostatic reproduction of the original of which is attached hereto as Exhibit "A" and made a part hereof. 4. Judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. 5. There has not been any assignment of the Note. 7' 6. Judgment has not been entered on the Note in any jurisdiction. 7. Defendant is in default of Defendant's obligations to make payment to the Plaintiff as required in the Note, and the Plaintiff has demanded payment in full of all outstanding amounts as provided in the Note. A copy of the Plaintiffs demand dated November 18, 2009, is attached hereto as Exhibit "B" and made a part hereof. 8. The amount due to the Plaintiff as a result of the Defendant's default is as follows: a. Principal $172,333.04 b. Interest to June 2, 2010 $ 7,195.09 C. Late Charges $ 2,113.72 d. Attorneys' Fees $ 17,952.81 TOTAL DUE: $199,594.66 9. Interest continues to accrue at a rate equal to the Prime Rate in effect on the first business day of the month in which an interest rate change occurs, as published in the Wall Street Journal on the next business day, plus two and one-quarter percent (2.250/o), adjusted monthly WHEREFORE, Plaintiff, PNC Bank, National Association, demands judgment against the Defendant, AAA Convenience, Inc., dba Uni-Mart, in the amount of One Hundred Ninety-Nine Thousand Five Hundred Ninety-Four and 66/100 Dollars ($199,594.66), plus interest at a rate equal to the Prime Rate in effect on the first business day of the month in which an interest rate change occurs, as published in the Wall Street Journal on the next business day, plus two and one-quarter percent (2.25%), adjusted monthly, through the date of payment, including on and after the date of entry of judgment on this Complaint, and for other expenses, fees and costs to which the Plaintiff may be entitled. I Respectfully submitted, McNees Wallace & Nurick LLC Date: June/ z 2010 By: G VC quire upreme 4848 100 Pine , ox 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, Plaintiff V. AAA CONVENIENCE, INC., DBA UNI-MART, Defendant DOCKET NO. CONFESSION OF JUDGMENT PREVIOUSLY ASSIGNED TO: N/A VERIFICATION I, Jay H. Jennison, Relationship Manager for PNC Bank, National Association, being authorized to do so on behalf of PNC Bank, National Association, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. INC BANK, NATIONAL ASSOCIATION Date: )*.kL? 17, ;?0w By: (Page 1 of 7) ut ?It) w e U.S. Small Business Atitninistmtion NOTE SBA Loan # PLP 87820940.00 SBA Loan Name W-Mart Date - af Loan Amount 303,800.00 Interest Rate Floating at WSJ Prime plus 2.25% resulting in an initial rate of 8.00% Borrower AAA Convenience, Inc. dba UnI401art Operating Company Lender PNC Bank, National Association 1. PROMISE TO PAY: In return for the Loan, Borrower promises to pay to the order of Lender the amount of Three Hundred Three Thousand Eight Hundred -- 00'100 Dollars, interest on the unpaid principal balance, and all other amounts required by this Note. 2. DEFINITIONS: "Collateral" mean any property taken as security for payment of this Note or any guarantee of this Note. "Guarantor" means each person or entity that signs a guarantee of payment of this Note. "Loan" means the loan evidenced by this Note. "Loan Documents" means the documents related to this loan signed by Borrower, any Guarantor, or anyone who pledges collateral. "SBA" means the Small Business Administration, an Agency of the United States of America. BOA Form 147 (00A OM VerWW 4.7 Page Ila Bankers Systems, Inc„ St Cloud, MN (Page 2 or 7) 3. PAYMENTTERMS: Borrower must make all payments at the place Lender designates. The payment terms fbr this Note are: This Note will mature In 10 years from date of Note. The interest rate on this Note wig fluctuate. The initial interest rate is 8.00% per year. This initial rate is the prime rate on the date SBA received the loan application, plus 2.25%. The Initial interest rate must rennin In effect untl the first change period begins. Borrower must pay interest on the disbursed principal balance, plus principal of $2,531.67 every month, beginning one month from the month this Note Is dated; payments must be made on the first calendar day in the months they are due. Lender will apply each installment payment first to pay interest accrued to the day Lender receives the payment, then to bring principal current, then to pay any late fees, and wM apply any remaining balance to reduce the principal. The interest rate will be adjusted monthly (the "change period"). The "Prime Rate" is the prime rate in effect on the first business day of the month in which an interest rate change occurs, as published in the Wall Street Journal on the next business day. The adjusted interest rate will be 2.25% above the Prime Rate. Lender will adjust the interest rate on the first calendar day of each change period. The change in interest rate is effective on that day whether or not Lender gives Borrower notice of the change. Lender must adjust the payment amount at least annually as needed to amortize principal over the remaining term of the note. If SBA purchases the guaranteed portion of the unpaid principal balance, the interest rate becomes fixed at the rate in effect at the time of the eariest uncured payment default. If there is no uncured payment default, the rate becomes fixed at the rate In effect at the time of purchase. Notwithstanding any provision in this Note to the contrary: Borrower may prepay this Note. Borrower may prepay 20 percent or less of the unpaid principal balance at any time without notice. If Borrower prepays more than 20 percent and the Loan has been sold on the secondary market, Borrower must" (a.) Give Lender written notice; (b.) Pay all accrued interest; and (c.) If the prepayment is received less than 21 days from the date Lender receives the notice, pay an amount equal to 21 days' interest from the date Lender receives the notice, less any Interest accrued during the 21 days and paid under subparagraph b., above. N Borrower does not prepay within 30 days from the date Lender receives the notice, Borrower must give Lender a new notice. All remaining principal and accrued Interest is due and payable 10 years from date of Note. Late Charge: if a payment on this Note is more than 10 days late, Lender may charge Borrower a late fee of up to 5% of the unpaid portion of the regularly scheduled payment. saA Form 147 (OafOW2) Version 4.1 fto 2!0 Bankers Systems, Inc., St. Cloud, MN (Page 3 of 7) 4. DBFAULT: Borrower is in default under this Note if Borrower does not make a payment when due under this Note, or if Borrower or Operating Company: A. Fails to do anything required by this Note and other Loan Documents; B. Defaults on any other loan with Lender, C. Does not preserve, or account to Lender's satisfaction for, any of the Collateral or its proceeds; D. Does not disclose, or anyone acting on their behalf does not disclose, any material fact to Lender or SBA; E. Makes, or anyone acting on their behalf makes, a materially false or misleading representation to Lender or SBA; F. Defaults on any loan or agreement with another creditor, if Lender believes the default may materially affect Borrower's ability to pay this Note; 0. Fails to pay any taxes when due; H. Becomes the subject of a proceeding under any bankruptcy or insolvency law; 1. Has a receiver or liquidator appointed for any part of their business or property; J. Makes an asaignment for the benefit of creditors; K Has any adverse change in financial condition or business operation that Lender believes may materially affect Borrower's ability to pay this Note; L. Reorganizes, merges, consolidates, or otherwise changes ownership or business structure without Lender's prior written consent; or M. Becomes the subject of a civil or criminal action that Lender believes may materially affect Borrower's ability to pay this Note. S. LENDER'S RIGHTS IF THERE IS A DEFAULT: Without notice or demand and without giving up any of its rights, Lender may: A. Require immediate payment of all amounts owing under this Note; B. Collect all amounts owing from any Borrower or Guarantor, C. File suit and obtain judgment; D. Take possession of any Collateral; or E. Sell, lease, or otherwise dispose of, any Collateral at public or private sale, with or without advertisement. 6. LENDER'S GENERAL POWERS: Without notice and without Borrower's consent, Lender may: A. Bid on or buy the Collateral at its sale or the sale of another Iienholder, at any price it chooses; B. Inenr expenses to collect amounts due under this Note, enforce the terms of this Note or any other Loan Document, and preserve or dispose of the Collateral. Among other things, the expenses may include payments for property taxes, prior liens, insurance, appraisals, environmental remediation costs, and reasonable attorney's fees and costs. If Lender incurs such expenses, it may demand immediate repayment fmm Borrower or add the expenses to the principal balance; C. Release anyone obligated to pay this Note; D. Compromise, release, renew, extend or substitute any of the Collateral; and E. Take any action necessary to protect the Collateral or collect amounts owing on this Note. SBA Point 947 (OBJ0.'f/02) V WWM 4.1 Page are Bankers Systems, Inc., St. Cloud, MN (Page 4 of 7) 7. WHEN FEDERAL LAW APPLIES: When SBA is the holder, this Note will be interpreted and enforced under federal law, including SBA regulations. i Lender or SBA may use state or local procedures for filing papers, recording documents, giving notice, foreclosing liens, and other purposes. By using such procedures, SBA does not waive any federal immunity from state or local control, penalty, tax, or liability. As to this Note, Borrower may not claim or assert against SBA any local or state law to deny any obligation, defeat any claim of SBA, or preempt federal law. 8. SUCCESSORS AND ASSIGNS: Under this Note, Borrower and Operating Company include the successors of each, and Lender includes its successors and assigns. 9. GENERAL PROVISIONS: A. All individuals and entities signing this Note arelointly and severally liable. B. Borrower waives all suretyship defenses. C. Borrower must sign all documents necessary at any time to comply with the Loan Documents and to enable Lender to acquire, perfect, or maintain Lender's liens on Collateral. D. Lender may exercise any of its rights separately or together, as many times and in any order it chooses. Lender may delay or forgo enforcing any of its rights without giving up any of them. E. Borrower may not use an oral statement of Lender or SBA to contradict or alter the written terms of this Note. i F. If any part of this Note is unenforceable, all other parts retrain in effect I G. To the extent allowed by law, Borrower waives all demands and notices in cormoction with this Note, including presentment, demand, protest, and notice of dishonor. Borrower also waives any defames based upon any claim that Lender did not obtain any guarantee; did not obtain, perfect, or maintain a lien upon Collateral; impaired Collateral; or did not obtain the fair market value of Collateral at a sale SBA Form 147 (0610aRM version 4.1 Paps 410 Bankers Systems, Inc., St. Cloud, MN (Page 5 of 7) 10. STATE-SPECIFIC PROVISIONS: 1. POWER TO CONFESS JUDGMENT. UNDERSIGNED HEREBY EMPOWERS ANY ATTORNEY OF ANY COURT OF RECORD, AT ANY TIME AFTER THE OCCURRENCE OF ANY EVENT OF DEFAULT HEREUNDER, TO APPEAR FOR THE UNDERSIGNED AND, WITH OR WITHOUT COMPLAINT FILED, CONFESS JUDGMENT, OR A SERIES OF JUDGMENTS, AGAINST THE UNDERSIGNED IN FAVOR OF THE LENDER OR ANY HOLDER HEREOF FOR THE ENTIRE PRINCIPAL BALANCE OF THIS NOTE, ALL ACCRUED INTEREST AND ALL OTHER AMOUNTS DUE HEREUNDER, TOGETHER WITH COSTS OF SUIT AND AN ATTORNEY'S COMMISSION OF 10% OF SUCH PRINCIPAL AND INTEREST ADDED AS A REASONABLE ATTORNEYS FEE, AND FOR DOING SO, THIS NOTE OR A COPY VERIFIED BY AFFIDAVIT SHALL BE A SUFFICIENT WARRANT. THE UNDERSIGNED HEREBY FOREVER WANES AND RELEASES ALL ERRORS IN SAID PROCEEDINGS AND ALL RIGHTS OF APPEAL AND ALL RELIEF FROM ANY AND ALL APPRAISEMENT, STAY OR EXEMPTION LAWS OF ANY STATE NOW IN FORCE OR HEREAFTER ENACTED. JUDGMENT MAY BE CONFESSED FROM TIME TO TIME UNDER THE AFORESAID POWER TO CONFESS JUDGMENT AND NO SINGLE EXERCISE OF THE FOREGOING POWER TO CONFESS JUDGMENT, OR A SERIES OF JUDGMENTS, SHALL BE DEEMED TO EXHAUST THE POWER, WHETHER OR NOT ANY SUCH EXERCISE SHALL BE HELD BY ANY COURT TO BE INVALID, VOIDABLE, OR VOID, BUT THE POWER SHALL CONTINUE UNDIMINISHED AND IT MAY BE EXERCISED FROM TIME TO TIME AS OFTEN AS THE LENDER SHALL ELECT UNTIL SUCH TIME AS THE LENDER SHALL HAVE RECEIVED PAYMENT IN FULL OF THE DEBT, INTEREST, COSTS AND FEES. 2. Governing Law; Jurisdiction. This Note will be interpreted and the rights and liabilities of the parties hereto determined In accordance with the laws of the Commonwealth of Pennsylvania, excluding its amflict of laws rules. The Undersigned hereby Irrevocably consents to the exclusive jurisdiction of the Courts of Common Pleas of the Commonwealth of Pennsylvania and the United States District Court for the Eastern District of Pennsylvania; provided that nothing contained in this Note will prevent the Lender or any holder hereof from bringing any action, enforcing any award or judgment or exercising any rights against the Undersigned, against any security or against any property of the Undersigned within any other county, state or other foreign or domestic jurisdiction. The Undersigned agrees that the venue provided above is the most oor venient forum for both the Lender and the Undersigned and the Undersigned waives any objection to venue and any objection based on a more convenient form In any action Instituted under this Note. The Undersigned agrees that service of process in any such proceeding may be duly effected upon the Undersigned by mailing a copy thereof by registered mail, postage prepaid, to the Undersigned. 3. WAIVER OF JURY TRIAL. THE UNDERSIGNED IRREVOCABLY WANES ANY AND ALL RIGHTS THE UNDERSIGNED MAY HAVE TO A TRIAL BY JURY IN ANY ACTION, PROCEEDING OR CLAIM OF ANY NATURE RELATING TO THIS NOTE, ANY DOCUMENTS EXECUTED IN CONNECTION WITH THIS NOTE OR ANY TRANSACTION CONTEMPLATED IN ANY OF SUCH DOCUMENTS. THE UNDERSIGNED ACKNOWLEDGES THAT THE FOREGOING WAIVER IS KNOWING AND VOLUNTARY. 8SA Form 147 (08103102) Vmbn 4.1 Page we Bankers Systems, Inc., St. Cloud, MN (Page 6 of 7) 11. BORROWER'S NAME(S) AND SIONATURE(S): By signing below, each individual or entity becomes obligated under this Note as Borrower. AAA Convenience, Inc. dba Uni-Mart See signature page attached ell SBA Form 147 (OGKW02) VWWon 4.1 Papa M Bankers Systems, inc.. St. Good, MN (Page 7 of 7) 1 i I I SIGNATURE PAGE: AAA CONVENIENCE, INC dba UNI-MART GED ABDELMALIK, ENT /? l' ADEL AS, VICE SIDENT I ? HANAN A A, SECRETARYfMASURER i PNCBANK November 18, 2009 MA IffiLUGULARMAIL AAA Convenience, Inc. dba Uni-mart 1004 Wesley Drive Mechanicsburg, PA 17055 Attention: Maeed Abdelmalik, President Adel Abbas, Vice President Hanan Awadalla, Secretary/Treasurer RE: DEMAND FOR PAYMENT Ladies and Gentlemen: As you know, AAA Convenience, Inc. dba Uni-mart (the "Borrower.) is obligated to PNC Bank, National Association (the "Bank'D for the following (the "Obligation"): a certain SBA guaranteed term loan in the original principal amount of $303,800.00 (the "Term Loan") as evidenced by a certain Note (the "Term Note'.'} from Borrower to the Bank dated April 15, 2005. A listing of the current principal balance and accrued interest and late charges owing as of the date immediately prior to the date of this letter for the Obligation and a per diem is enclosed with this letter as Exhibit "A". - As you know, the Obligation is currently past due from the Borrower's failure to timely pay principal and interest payments for the months of September, October, and November 2009. With this letter, we DEMAND IMMEDIATE PAYMENT of all sums owing to us under the Obli ation. If we do not receive payment in full in immediately available funds of the amounts outlined in Exhibit A plus per diem interest by the close of business on November 26, 2009 or if we have not agreed in writing upon an acceptable payment plan for the payment of the Obligation with the Borrower by that date, we will consider taking all actions we deem appropriate to collect the Obligation and protect our collateral. cc: Maged Abdelmalik, Guarantor-VIA CERTIFIED AND REGULAR MAIL Adel Abbas, Guarantor- VIA CERTIFIED AND REGULAR MAIL Hanan Awadalla,' Guarantor- VIA CERTIFIED AND REGULAR MAIL Cyd B. Wolf, Esquire EXHIBIT A COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, : DOCKET NO. ID - y/ / ?. `?crw Plaintiff : n a v. : CONFESSION OF JUDGMENT rt C-- 9 AAA CONVENIENCE, INC., DBA : N 1 c C? UNI-MART, Defendant PREVIOUSLY ASSIGNED TO: CERTIFICATE OF ADDRESSES I hereby certify that the precise address of the Plaintiff, PNC Bank, National Association, is 4242 Carlisle Pike, Camp Hill, PA 17011; and that the last known address of the Defendant, AAA Convenience, Inc., dba Uni-Mart, is 1004 Wesley Drive, Mechanicsburg, PA 17055. Respectfully submitted, Date: June lL 2010 McNees Wallace & Nurick LLC By: St freme Court ID 4848 100 Pine Street, P, Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. ?Q - g160 Plaintiff V. CONFESSION OF JUDGMENT AAA CONVENIENCE, INC., DBA 9 UNI-MART, C= r, W C_ Fri PREVIOUSLY ASSIGNED TO: AW z AFFIDAVIT OF NON-MILITARY SERVICE TO THE PROTHONOTARY: cx? I do certify, to the best of my knowledge, that the Defendant in the above-captioned action, AAA Convenience, Inc., dba Uni-Mart, is not presently on active or nonactive military status. Respectfully submitted, McNees Wallace & Nurick LLC Date: June 17, 2010 By: ffr uff. Esq re eme ourt ID 02 848 100 Pine Street, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. l Q 4110 / 6y; . f? Plaintiff V. CONFESSION OF JUDGMENT AAA CONVENIENCE, INC., DBA UNI-MART, Defendant PREVIOUSLY ASSIGNED TO: N/A NOTICE UNDER RULE 2958.1 ? cz OF JUDGMENT AND EXECUTION THEREON' J NOTICE OF DEFENDANT'S RIGHTS C 19.0 TO: AAA Convenience, Inc., dba Uni-Mart A judgment in the amount of $199,594.66, plus interest, other expenses, fees and costs h as been entered against you and in favor of the plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Respectfully submitted, McNees Wallace & Nurick LLC Date: June/7, 2010 By: ff, Esquire *Wpreme Co ID #24848 100 Pine Street, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. J O -- ql?„l Ci,/l Plaintiff V. CONFESSION OF JUDGMENT AAA CONVENIENCE, INC., DBA UNI-MART, ; Defendant PREVIOUSLY ASSIGNED TO: N/A PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Plaintiff, PNC Bank, Nati onal Association. Papers may be served at the address set forth below . c.. Geoffrey S. Shuff, Esquire cz?, r? e rs) McNees Wallace & Nurick LLC 100 Pine Street, PO Box 1166 Harrisburg, PA 17108-1166 00 '• (717) 237-5439 -?: Respectfully submitted, Date: June r, 2010 McNees Wallace & Nurick LLC By: rjeo ,kf,YS- S uff, Esquire -Salfferne C ID #24848 100 Pine eet, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff ?c td-7, j-() / A , 71 ?? a yyo I I L COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, Plaintiff V. AAA CONVENIENCE, INC., DBA UNI-MART, Defendant DOCKET NO. CONFESSION OF JUDGMENT PREVIOUSLY ASSIGNED TO: N/A To: AAA Convenience, Inc., dba Uni-Mart, Defendant You are hereby notified that on 22 2010, judgment by confession was entered against you in the sum of $199,594.69, in the above-captioned case. DATE: P thonotary 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 I hereby certify that the following is the address of the Defendant stated in the certificate of residence: AAA Convenience, Inc., dba Uni-Mart 1004 Wesley Drive Mechanicsburg, PA 17055 t!!yAcSSUffx-A-ttorney for Plaintiff A, AAA Convenience, Inc., dba Uni-Mart, Demandado: Por este medio usted sea avisado que en el dia _ de de 2010, un juicio por admision fue registrado contra usted por la cantidad de $199,594.66, referente al caso mencionado arriba. FECHA: Protonotario LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O SI NO TIENE EL DINERO PARA PAGAR TAL SERVICIO, VAYA PERSONALMENTE O LLAME POR TELEFONO A LA OFICINA CUYO TELEFONO Y DIRECCION SE ENCUENTRAN ESCRITOS ABAJO PARA AVERIGUAR DONDE USTED PODRA CONSEGUIR ASISTENCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Por este medio certifico que la siguientes son las direcciones de los demandado, dicho en el certificado de residencia: AAA Convenience, Inc., dba Uni-Mart 1004 Wesley Drive Mechanicsburg, PA 17055 Geo ey . S 7 6 del Demandante ~ i COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, :DOCKET NO. 10-4161 Civil Term Plaintiff ; v :CONFESSION OF JUDGMENT ~ ~ :~~ r AAA CONVENIENCE, INC., DBA ~ o .~ UNI-MART -ta ~-,-, `-- =~- -~-~ ~~ ~ , s._- n~ ~ Defendant :PREVIOUSLY ASSIGNED TO: 1/~ , ~'? `~" f ~ ~ ? ; •. _ ,,. ~.:: -v _' RETURN OF SERVICE PURSUANT TO `~ ~- ' ~ `~' ~ c_. ~ _ , PA. R.C.P. No. 2958.1(c) z ~, ~ -c Plaintiff, PNC Bank, National Association, hereby files this Return of Service and swears and affirms that the person or persons listed below was or were served pursuant to Pa. R.C.P. No. 2958.1(b) with the Notice of Judgment and Execution Required by Rule 2958.1 by certified mail, return receipt requested, as provided by Pa. R.C.P. No. 403. A copy of each receipt for certified mail is attached hereto. AAA Convenience, Inc., dba Uni-Mart 1004 Wesley Drive Mechanicsburg, PA 17055 Date: July 1, 2010 McNees Wallace & Nurick LLC By: ~e ey S huff, Esquire prem ourt ID #24848 100 Pi a Street, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff 7160 3901 9848 5253 8106 TQ; AAA Convenience, Inc., dba Uni-Mart 1004 Wesley Drive Mechanicsburg, PA 17055 SENDER: Geoffrey S. Shuff REFERENCE: PNC Bank PS Form 3800. Janusrv 2006 RETURN Postage ~ RECEIPT Certifted Fee Z . QO SERVICE Return Receipt Fee e7 Restricted Delivery , Total Postage ~ Fees . r~ US Postal Service POSTMARK®TE ~ ?,,`'~ Receipt for / '~ ~ . ~ s~ti, - of ~, Certified Mail ~ ~"~ No Insurance Coverage Provided Do Not Use for Internati n l M il ,. ~ ~ c~ '' ~? o a a ` : b~` nt r. ~ Geoffrey S. Shuff ^ Addressee ^ Yes