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Home My WebLink About01-1726 M & T BANK, formerly : IN THE COURT OF COMMON PLEAS FIN~C~ TRUST COMPANY : ., Plaintiff : COUNTY OF CUMBERLAND ' COMMONWEALTH OF · PENNSYLVANIA VS. . · CIVIL ACTION LAW DENNIS R. HAMILTON · Defendant : CIVIL TERM 2001 - /'~-~ TO DENNIS R. HAMILTON, Defendant You are hereby notified that on March ~ Z~o 2001, judgment by Confession was enteretl against you in the sum of $ 2,504.01 in the above- captioned case. Prothonotary YOU SHOULD TAKE THIS PAPER TO YOUR LAW~R AT ONCE. IF YOU DO NOT HAVE A LA~ER OR CANNOT AFFO~ ONE, ~ TO OR TELEPHO~ THE OFFICE SET FORTH BELOW TO FIND OUT WHE~ YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 717-249-3166 M & T BANK, formerly : IN THE COURT OF COMMON PLEAS FINANCIAL TRUST COMPANY · Plaintiff ' COUNTY OF CUMBERLAND : COMMONWEALTH OF · PENNSYLVANIA VS. · : CIVIL ACTION LAW DENNIS R. HAMILTON : Defendant : CIVIL TERM ~001- / CONFESSION OF JUDG~NT Pursuant to the Warrant of Attorney contained in the aforementioned Promissory Note, the original or copy of which is attached to the Complaint f'ded in this action, I appear for the Plaintiff and confess judgment in favor of Plaintiff and against the Defendant, Dennis R. Hamilton, as follows: Principal Amount due to date: $ 1,854.~2 Interest Accrued and unpaid through March 21, 2001 $ 117.41 Late Charges $ 32.08 Attorney's Fee's Pursuant to the terms of the Note $ ~00.00 TOTAL $ 2,504.01 with interest from March 21, 2001, on the sum of $ 2,~04.01 at the rate of 9.~0 % per annum. Respectfully submitted, Duncan & Hartman, P.C. Dated: ~ ~,~ 4~) 1 ~lliam A. Duncan, Esquire PA ID # 22080 Attorney for Plaintiff M & T BANK, formerly : IN THE COURT OF COMMON PLEAS FINANCIAL TRUST COMPANY : Plaintiff : COUNTY OF CUMBERLAND : COMMONWEALTH OF : PENNSYLVANIA VS. : : CIVIL ACTION LAW DENNIS R. HAMILTON : Defendant · CIVIL TERM 2001 o / ? ~ ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter our appearance on behalf of Plaintiff, M & T Bank, formerly Financial Trust Company, and enter judgment for Plaintiff and against Defendant Dennis R. Hamilton for damages. Duncan & Hartman, P.C. {~'~li~un A. Duncan, Esquire Attorney for Plaintiff M & T BANK, formerly · IN THE COURT OF COMMON PLEAS FINANCIAL TRUST COMPANY : Plaintiff : COUNTY OF CUMBERLAND : COMMONWEALTH OF : PENNSYLVANIA VS. · : CIVIL ACTION LAW DENNIS R. HAMILTON : Defendant : CIVIL TERM 2001 - / ? ~_ ~ COMPLAINT FOR JUDGMENT BY CONFESSION PURSU~ TO PENNSYLVANIA RULES OF CIVIL PROCEDURE 2951, ET SEQ. Plaintiff, M & T Bank, formerly Financial Trust Company, by its attorney, William A. Duncan, files this Complaint in Confession of Judgment. 1. Plaintiff, M & T Bank, formerly Financial Trust Company, is a Pennsylvania banking Corporation existing under the laws of the Commonwealth of Pennsylvania, with its principal place of business located at 141~ Ritner Highway, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Dennis R. Hamilton, with a last known address of 160 East North Street, Carlisle, Cumberland County, Pennsylvania, 17013. '3. On or about October 23, 1998, Defendant, Dennis R. Hamilton, entered into a Promissory Note in favor of Plaintiff, Financial Trust Company, now by merger, M & T Bank, in the original principal amount of Five Thousand and 00/100 ($~,000.00) Dollars. A true and correct copy of the Note, which contains the Warrant of Attorney upon which this judgment is confessed, is attached hereto as Exhibit "A" and is a part hereof. 4. Defendant Dennis R. Hamilton, has defaulted in this obligation under the Note by failing to make his August, September, October, November, December 2000, payments as well as January and February 2001, payments of principal and interest due thereunder the terms of said Note. 5. Pursuant to the Note, judgment may be entered against Defendant Dennis R. Hamilton for ali monies due without notice or demand. 6. Pursuant to the Note, and by reason of Defendant Dennis R. Hamilton's default, the following amounts are currently due and owing Plaintiff M & T Bank, formerly Financial Trust Company by Dennis R. Hamilton, Defendant. Principal Amount due to date: $ 1,854.52 Interest Accrued and unpaid through March 21, 2001 $ 117.41 Late Charges $ 32.08 Attorney's Fee's Pursuant to the terms of the Note $ 500.00 TOTAL $ 2,504.01 Interest accrues at n rate of $0.49 for each day after March 21, 2001 that this indebtedness remains unpaid. In an event of a petition to strike or open this judgment is f'ded, Plaintiff M & T Bank, formerly Financial Trust Company, reserves the right to have interest and attorney's fees brought current. 7. There has been no assignment of the Note. 8. Judgment has not been entered on the Note in any other jurisdiction. 9. Pursuant to the Note, $2,504.01 is currently due and owing Plaintiff M & T Bank, formerly Financial Trust Company, from Defendant Dennis R. Hamilton, and Defendant Dennis R. Hamilton, has failed to pay the amount due. WHEREFORE, Plaintiff M & T Bank, formerly Financial Trust Company, request that judgment be entered in its favor and against Defendant Dennis R. Hamilton, in the sum of $2,504.01 and all costs of suit. Duncan & Hartman, P.C. L/~N~il~ia~- ~-. Duncan, Esquire Attorney for Plaintiff ~VE~CA~ON I, JOHN P. STOVER, hereby verify that I am a Special Assets Loan Workout Officer, for M & T Bank, that I make this verification being authorized to do so, and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 1.8 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. wo, o , .M& TBank .o CERTIFICATION OF COMMI~RCIAI~ TRANSACTION I, John P. Stover, hereby verify that I am a Loan Workout Officer, o£M & T Bank, and, as such, duly authorized representative elM & T Bank, deposes and says subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities that the underlying transa~on relative to this Complaint in Confession of Judgment is a commercial transaction to the best of his knowledge, information and belie[ ~&T Bank~rk°ut Offi¢~ I~R-12-2001 11 '06PM FROM-M&T COM LOAN 600-260-2443 T-246 P.OOZ/OOT F-TOO ,, PROMISSORY NOTE- _.,:~;. · .... ~,-.7~. =.- ..... -,--". ~ ~~:_::l~.~~~.f:~"~~~'~ '"~~~~-~,~ ~=~_~?~~'. .- ... ..... ~ . ~.. .~ .......... . ......... ~ ~.~ ~t ~C T~~ · - ' ~ '--"'" .... ~ .... ""' ' ......" ' .... - ..... ' O,TE '~/..'-~-'.~..".'--' " ~in~~ ~~ ~,~.~ · .' .... I~ R~: ~ .." O~ of ~~: O~r M~ ~: .O~~r ... . . ~ .W .~~m !aw, ~y~~ .~a ~e .a~~ ~. m. ~~ ~. in~ ~q to ~~~, ~d any ~i~ ~~ ~~ ~ a ~~nt k. 15 ~ u ~ Ii, ~v ~ be ~~ed ~ ~ ~ ~~ ~ ~.... ~~T. B~ ~i ~ in ~ul g ~ ~ ~ ~~ ~ ia) B~~ ~ ~ ~ any ~ .~ d~ .la) ~~ b~~ any ~~ ~n~' ~ Bfld. ~~s Km ~ .~'~ ~ ~ b' G..K~, ,~~ a~'.~ and ~d v~ ~ ~ ~ ~ ~y ~ ~~ ~ a~ d ~ B~ may o~fl.in ~ ~, ~ ~ ... P~' IN~~. 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