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HomeMy WebLinkAbout11-1095TWO BEER GUYS, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW BRUCE DOUPE and SHANNON DOUPE h b d d fe U3 an an w i fl KONSTANTINOS PANAGAKIS and 3 KRISTIN PANAGAKIS, husband and rnCO C-- =-q :zm Wife, r- -am Defendants n od' CONFESSION OF JUDGMENT c) Pursuant to the authority contained in the warrant of attorney, 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 Defendants as follows: Unpaid balance of principal $ 16,326.46 Interest from 5/31 /10 to 1/3 1 /11 Plus continuing interest at 8% per month $ 979.59 Attorney's Collection Fee $ 1,500.00 Total Amount Due $ 18,806.05 Shelly J. K4hkel, Esquire WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 (717) 236-9301 Judgment Entered as Above On 2011. Prothonotary aN? aµk aai. lb 14 Ck+ 11131 ??asyye3 ?Jo?i'cc Jacu.lt? WION, ZULLI & SEIBERT Shelly J. Kunkel, Esquire PA ID # 64485 109 Locust Street F1-E0-0F'FIC OF THE PR TF 2Q?IJN31 RM4: CUMBERLAND COUNT)" PENNSYL%'AHIA Harrisburg, PA 17101 (717) 236-9301 (717) 236-6100 (fax) TWO BEER GUYS, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACT IONQ-yLAW _ BRUCE DOUPE and NO. ab), -ICI5 Cl v i?f SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, . Defendants 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. 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17103 1-800-990-9108 (717) 249-3166 WION, ZULLI & SEIBERT Shelly J. Kunkel, Esquire PA ID # 64485 109 Locust Street Harrisburg, PA 17101 (717) 236-9301 (717) 236-6100 (fax) TWO BEER GUYS, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Plaintiff CIVIL ACTION - LAW BRUCE DOUPE and NO. SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, Defendants AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17103 1-800-990-9108 (717) 249-3166 WION, ZULLI & SEIBERT Shelly J. Kunkel, Esquire PA ID # 64485 109 Locust Street Harrisburg, PA 17101 (717) 236-9301 (717) 236-6100 (fax) TWO BEER GUYS, LLC, Plaintiff V. BRUCE DOUPE and SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. COMPLAINT FOR CONFESSION OF JUDGMENT PURSUANT TO Pa. R.C.P. 2952 AND NOW, this day of January, 2011, comes Plaintiff, Two Beer Guys, LLC, by and through its attorney, Wion, Zulli & Seibert and Shelly J. Kunkel, Esquire, and files the within Complaint for Confession of Judgment Pursuant to Pa. R.C.P. 2952, and in support thereof states the following: 1. The Plaintiff, Two Beer Guys, LLC, is a Pennsylvania limited liability company with a business address at 330 W. Aaron Drive, State College, Pennsylvania, 16803. 2. The Defendants, Bruce Doupe and Shannon Doupe, are married individuals who reside at 960 Alexander Spring Road, Carlisle, Pennsylvania, 17015. 3. The Defendants, Konstantinos Panagakis and Kristin Panagakis, are married individuals who formerly resided at 42 Westwood Ct., Enola, PA 17025 and who now are currently believed to reside at 47 Sherwood Circle, Enola, PA 17025. 4. A Promissory Judgment Note dated September 11, 2009, was executed by Defendants in favor of Two Beer Guys, LLC and delivered to Plaintiff concurrently. A true and correct copy of the Promissory Judgment Note is attached hereto and incorporated herein as "Exhibit All. 5. The Promissory Judgment Note is in default because the monthly payments of principal only amounting to $250.00, which became due and payable on September 30, 2009 and on the same day of each month thereafter, have not been made, and by the terms of said note, upon default in such monthly payments, the whole of said note debt shall, at the option of the Plaintiff, become due and payable forthwith. 6. Additionally, pursuant to the terms of Paragraph 4 of the Promissory Judgment Note, in the event of default by Defendants, interest shall accrue on the unpaid principal balance at a rate of eight (8%) percent per annum from the time of default and acceleration until the Defendants' indebtedness to the Plaintiff is paid in full, including the period following entry of any judgment against Defendants as provided for in said note. 7. Judgment is not being entered by confession against a natural personal in connection with any consumer credit transaction as defined by PA R.C.P. 2950, since the amounts due under this Promissory Judgment Note represent the deficiency balance resulting from a short sale of real property acquired by and renovated by Defendants for use as an investment property which acquisition and renovation was financed by Plaintiff. 8. The aforesaid Promissory Judgment Note has not been entered in any other jurisdiction. 2 9. The Defendants are liable to the Plaintiff as follows: Unpaid balance of principal $ 16,326.46 Interest from 5/31/10 to 1/31/11 plus continuing interest at 8% per month $ 979.59 Attorney's Collection Fee $ 1,500.00 Total Amount Due $ 18,806.05 WHEREFORE, Plaintiff requests the entry of judgment in favor of the Plaintiff and against the Defendants in the sum of $ 18,806.05 as authorized by the warrant appearing in the attached Promissory Judgment Note. Date: Respectfully submitted, Y? Shelly J. nkel, Esquire Attorney for Plaintiff WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 (717) 236-9301 (717) 236-6100 (fax) 3 EXHIBIT A PROMISSORY JUDGMENT NOTE $18,076.46 Date: September 11, 2009 FOR VALUE RECEIVED, AND INTENDING TO BE LEGALLY BOUND, Bruce Doupe, with an address of 960 Alexander Spring Road, Carlisle, PA 17015, and Shannon Doupe, with an address of 960 Alexander Spring Road, Carlisle, PA 17015, and Konstantinos Panagakis, with an address of 42 Westwood Ct, Enola, PA 17025, and Kristin Panagakis, with an address of 42 Westwood Ct, Enola, PA 17025, individually, jointly and severally, and collectively (hereinafter "Makers'), hereby promise to pay to Two Beer Guys, LLC, whose business address is 330 W. Aaron Drive, State College, PA 16803, (hereinafter "Payee) the principal sum of Eighteen Thousand Seventy Six Dollars and 00/100 ($18,076.46), as hereinafter set forth: Payment of Principal and Interest 1. Principal and interest shall be payable in lawful money of the Ui dited States of America, at office of Payee or such other place as the Holder of the Note may designate, in the following manner: a. Payments, consisting of principal, shall be made on a monthly basis in the amount of 250.00 per month; b. The first payment shall commence on September 30, 2009 and continue on the . same day of each month thereafter for a period of Seventy Two (72) months; c. A final balloon payment, consisting of all remaining principal amounts shall be due on or before August 30, 2015 ($326.46). Unless accelerated, this Promissory Judgment Note shall mature, and the principal sum and all accrued and unpaid interest thereon and all other fees and charges due hereunder shall be due and payable on August 30, 2015. Right to Prepay 2. The Makers shall have the privilege or right at any time to prepay, without penalty, this Note in whole or in part without the express written consent of the Payee or other holder of this Note. The Note Holder will use all of our prepayments to reduce the amount of principal that we owe under this Note. If we make a partial prepayment, there will be no changes in the due date or in the amount of our monthly payment unless the Note Holder agrees in writing to those changes. Obligations Under this Note I If more than one person or entity signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed, the obligations being Joint and Several. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that ay one of us may be required to pay all of the amounts owed under his Note. Events of Default 4. If the Makers fail to pay any sum when due or if the Makers shall in any other way be in default under this note, then the entire unpaid principal balance of this Note, together with interest accrued and with all other sums due or owed by the Makers under this Note or under the terms of any related Mortgage shall at the option of the Payee and without notice to the Maker become due and payable immediately with interest. After the default and acceleration and until the Makers' indebtedness to the Payee is paid in full, including the period following entry of any judgment, interest shall continue to accrue on the unpaid principal balance at a rate of eight (8%) percent per year in excess of the rate specified above. The Makers shall also be liable for attorney's fees for collection of the Note in the amount of five (5%) percent of the total amount then due by the Makers to the Payee, but in any event not less than One Thousand Five Hundred ($1,500.00) Dollars, and the cost of any title search incurred by the Payee in connection with the proceedings. Payment of these amounts may be enforced and recovered by the entry of judgment on this Note and the issuance of execution on the judgment. Confession of Judgment 5. The Makers hereby irrevocably authorize and empower any attorney or attorneys or the Prothonotary or Clerk of any court of record in the Commonwealth of Pennsylvania, or elsewhere, to appear for the Makers in any court in an appropriate action brought against Makers at the suit of the Payee on this Note, and to confess judgment against the Maker for all sums due 2 by the Maker together with costs of suit and attorneys' fees of five (5%) percent of the total amount of principal, interest and other charges due, with a minimum fee of One Thousand Five Hundred ($1,500.00) Dollars for collection. This Note or a copy of this Note verified by affidavit shall be a sufficient warrant. This warrant of attorney shall be effective whether or not this Note is in default. Remedies 6. The remedies of the Payee provided in this Note or otherwise available to the Payee at law or in equity and the warrants of attorney herein or therein contained, shall be cumulative and concurrent, and may be pursued singly, successively, and together at the sole discretion of the Payee, and may be exercised as often as occasion therefore shall occur. The failure to exercise any right or remedy shall in no event be construed as a waiver or release of the right or remedy. Waivers . 7. The Makers hereby release the Payee and the attorney or attorneys from all errors, defects, and imperfections in entering judgment by confession, issuing any process, or instituting any proceedings relating to the confession of judgment. Except as otherwise required by the terms of this note, the Makers (and all endorsers, sureties, and guarantors) waive presentment for payment, demand, notice of demand, notice of nonpayment or dishonor, protest, and notice of protest of this note, and all other notices in connection with the delivery, acceptance, performance, default or enforcement of the payment of this Note. Liability under this note shall be unconditional and shall not be affected in any manner by any indulgence, extension of time, renewal, waiver or modification granted or consented to by the Payee. Parties 8. The words "Payee" and "Maker" in this Note shall be deemed and construed to include the respective heirs, personal representative, successors, and assigns of the Payee and the Makers. The obligation of the persons named as Makers shall be joint and several. Construction 9. This instrument shall be construed according to and governed by the laws of the Commonwealth of Pennsylvania. 3 Limitation on Interest . 14. Notwithstanding any provision contained in this Note, the Makers' liability for the payment of interest shall not exceed the limits now imposed by the applicable usury law. If any provision of this Note requires interest payments in excess of the highest rate permitted by law, the provision shall be deemed to require only the highest payment permitted by law. Any amounts received by the Payee in excess of the maximum amount of interest permitted shall be applied by the Payee in reduction of the outstanding principal. In this case, any applicable prepayment prohibition or premium shall be waived with respect to the amount prepaid. If this Note shall have been paid in full, the amount of the excess shall be promptly returned by the payee to the Makers. IN WITNESS WHEREOF, the Makers have duly executed this Promissory Judgment Note under seal on the day and year first written above. WITNESS: 4 Commonwealth of Pennsylvania ) //?? ? ) ss. County of ?'.H a.*j ) On this l 7 day of September, 2009 before me appeared Bruce Doupe, to me known to be the person(s) described in and who executed the foregoing instrument and acknowledged that he executed the same as his free act and deed. In testimony whereof, I have hereunto _s y hand and affixed my o ial seal in the City and State aforesaid, the day and year - `t written above. Notary Public ? F ua?vi. ? PMG canes ao,so?a 5 Commonwealth of Pennsylvania ) ss. County of ?u bs,-? a ) On this [ ay of September, 2009 before me appeared Shannon Doupe, to me known to be the person(s) described in and who executed the foregoing instrument and acknowledged that she executed the same as her free act and deed. In testimony whereof, I have hereunto set _my.han xe official seal in the City and State aforesaid, the day and year firs fen above. Notary Public OFERiLWLVANIA ?Nnir 1t. ? sorry i rodlrMMoi iTWp.,WOMWMO&AW am» 6 Commonwealth of Pennsylvania } ss. County of ??-"?'` -?--- ) On this q day of ,5epensr, 2009 before me appeared Konstantinos Panagakis, to me known to be the person(s) described in and who executed the foregoing instrument and acknowledged that he executed the same as his free act and deed. In testimony whereof, I have hereunto set my band and affixed my official seal in the City and State aforesaid, the day and year first written above. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seat Midwel F Wise, NoWy pub WdWksbu,y dom, Cum wWA - My Commission J?n,??;',?Rt?! 7 Commonwealth of Pennsylvania ) ss. County of C? ) ©cfotlSLio On this day of-Segr, 2009 before me appeared Kristin Panagakis, to me known to be the person(s) described in and who executed the foregoing instrument and acknowledged that she executed the same as her free act and deed. In testimony whereof, I have hereunto set my hand and affixed my official seal in the City and State aforesaid, the day and year first written above. Notary Public VAVft- .J 8 FILED-OFfi IH WION, ZULLI & SEIBERT OF THE PROTHONOTAR.N( Shelly J. Kunkel, Esquire 2011 JAN 31 PM 4- 08 PA ID # 64485 109 Locust Street CUMBERLAND COUNT, Harrisburg, PA 17101 PENNSYLVANIA (717) 236-9301 (717) 236-6100 (fax) TWO BEER GUYS, LLC, Plaintiff V. BRUCE DOUPE and SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 201t-lbot Crvi/ rr.pl CERTIFICATE OF ADDRESSES Shelly J. Kunkel, Esquire, attorney for Two Beer Guys, LLC, certifies that the present business address of Plaintiff is 330 W. Aaron Drive, State College, Pennsylvania, 16803 and that the last known address of Defendants, Bruce Doupe and Shannon Doupe, is 960 Alexander Spring Drive, Carlisle, PA 17015-7909 and that the last known address of Defendants, Konstantinos Panagakis and Kristin Panagakis is 47 Sherwood Circle, Enola PA, 17025-1838. Shelly J. el, Esquire Dated: 1 1 Q / FILED-OFFICE OF THr PROTHONOTAR ,' WION, ZULLI & SEIBERT 2011 JAN 31 PM 4: 0 Shelly J. Kunkel, Esquire PA ID # 64485 CUMBERLAND COUNTY 109 Locust Street PENNSYLVANIA Harrisburg, PA 17101 (717) 236-9301 (717) 236-6100 (fax) TWO BEER GUYS, LLC, V. Plaintiff BRUCE DOUPE and SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. aUQ, AFFIDAVIT OF NON-MILITARY SERVICE Shelly J. Kunkel, Esquire, being duly sworn according to law, deposes and says that she is an officer of Plaintiff; that she is authorized to make this Affidavit on behalf of Plaintiff, Two Beer Guys, LLC, and that Defendant Bruce Doupe is not in the Military Service of the United States, nor any State or Territory thereof or its allies, as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Sworn to and subscribed before this 7 day oof/ ,uCA?7v 2011. Notary` Public PENNI9YLVANIA °+AR;AL SEAL Kv PL:b!ic LkAy c; j, ^w,jphin Cotinty Commis ,icn Tres March 19, 2014 Shelly J. unkel, Esquire WION, ZULLI & SEIBERT Shelly J. Kunkel, Esquire PA ID # 64485 109 Locust Street Harrisburg, PA 17101 (717) 236-9301 (717) 236-6100 (fax) TWO BEER GUYS, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Plaintiff CIVIL ACTION - LAW BRUCE DOUPE and NO. SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, Defendants AFFIDAVIT OF NON-MILITARY SERVICE Shelly J. Kunkel, Esquire, being duly sworn according to law, deposes and says that she is an officer of Plaintiff; that she is authorized to make this Affidavit on behalf of Plaintiff, Two Beer Guys, LLC, and that Defendant Shannon Doupe is not in the Military Service of the United States, nor any State or Territory thereof or its allies, as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Sworn to and subscribed before we this o? 71&1 day o 2011. Zia ?-Z4.-Z Notary Public PEAL t r.? thin Coiniy M Carr irn r ?res ill; 19, 2014 Shelly J. kuhkel, Esquire WION, ZULLI & SEIBERT Shelly J. Kunkel, Esquire PA ID # 64485 109 Locust Street Harrisburg, PA 17101 (717) 236-9301 (717) 236-6100 (fax) TWO BEER GUYS, LLC, V. Plaintiff BRUCE DOUPE and SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. I(- Ib1:5 AFFIDAVIT OF NON-MILITARY SERVICE Shelly J. Kunkel, Esquire, being duly sworn according to law, deposes and says that she is an officer of Plaintiff, that she is authorized to make this Affidavit on behalf of Plaintiff, Two Beer Guys, LLC, and that Defendant Konstantinos Panagakis is not in the Military Service of the United States, nor any State or Territory thereof or its allies, as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto.(,,:,. ) Shelly J. I nkel, Esquire Sworn to and subscribed before me this -?v 744 day o,zu?t, 2011. f2r? ? Ott 2'??? Nota y Public 'j rr'"C1?iC „, + Cesn?y ?vi v t,. +Gi3 ?:.'.;r7i+^J I?iaPGil 19, 2Q14 WION, ZULLI & SEIBERT Shelly J. Kunkel, Esquire PA ID # 64485 109 Locust Street Harrisburg, PA 17101 (717) 236-9301 (717) 236-6100 (fax) TWO BEER GUYS, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Plaintiff CIVIL ACTION - LAW BRUCE DOUPE and NO. SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, Defendants AFFIDAVIT OF NON-MILITARY SERVICE Shelly J. Kunkel, Esquire, being duly sworn according to law, deposes and says that she is an officer of Plaintiff; that she is authorized to make this Affidavit on behalf of Plaintiff, Two Beer Guys, LLC, and that Defendant Kristin Panagakis is not in the Military Service of the United States, nor any State or Territory thereof or its allies, as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Shelly J. unkel, Esquire Sworn to and subscribed before me this - 1Ef day 2011. Notaf/y Public S7 1_ .v n Ccjniy IN{m;b 19,6014 TWO BEER GUYS, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS BRUCE DOUPE AND SHANNON DOUPE, HUSBAND AND WIFE and KONSTANTINOS PANAGAKIS AND KRISTIN PANAGAKIS, HUSBAND AND WIFE DEFENDANT NO. CIVIL ACTION - To BRUCE DOUPE, Defendant(s) You are hereby notified that on 1128111, the following El Order El Decree ® Judgment has been entered against you in the above captioned case. Money Judgment in the amount of $18,806.05 DATE: ( - ?( -1 Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: BRUCE DOUPE 960 ALEXANDER SPRING ROAD CARLISLE, PA 17015-7909 A BRUCE DOUPE, Defendido/a Defendidos/as Por este medio se le esta notificando que el de del el/la siguiente ? Orden ? Decreto ® Fallo ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: 1128111 Prothonotario Certifico que la siguiente direccion es la del defendido/a sigun indicada en el certificado de residencia: BRUCE DO UPE 960 ALEXANDER SPRING ROAD CARLISLE, PA 17015-7909 Abogado del Demandante Rule 236(a) (2) Proth.-78 TWO BEER GUYS, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. BRUCE DOUPE and SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, Defendants CIVIL ACTION - LAW NO. c2b 11-109,5' ei 14' l 7?e n4.1 TO: BRUCE DOUPE, Defendant You are hereby notified that on 1-51-8 , judgment by confession was entered against you in the sum of $18,806.05, in the above-captioned case. Date: r notary 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 32 South Bedford Street Carlisle, PA 17103 1-800-990-9108 (717) 249-3166 I hereby certify that the following is the address of the defendant stated in the certificate of residence: 960 Alexander Spring Road Carlisle, Pennsylvania 17015-7909 3c? k-, Shelly J. K el, Esquire Attorney for Plaintiff TWO BEER GUYS, LLC, IN THE COURT OF COMMON PLEAS OF CIMERL4ND COUNTY, PENNSYLVANIA PLAINTIFF VS BRUCE DOUPE AND SHANNON DO UPE, HUSBAND AND WIFE and KONSTANTINOS PANAGAKIS AND KRISTIN PANAGAKIS, HUSBAND AND WIFE DEFENDANT NO. CIVIL ACTION - To KONSTANTINOS PANAGAKIS, Defendant(s) You are hereby notified that on 1128111, the following ? Order ? Decree ® Judgment has been entered against you in the above captioned case. Money Judgment in the amount of $18,806 05 DATE: ( '-31 -t/ I hereby certify that the name and address of the proper person(s) to receive this notice is: KONSTANTINOS PANAGAKIS 47 SHERWOOD CIRCLE ENOLA, PA 17025-1838 A KONSTANTINOS PANAGAKIS, Defendido/a Defendidos/as Por este medio se le esta notificando quo el de del el/la siguiente ? Orden ? Decreto ® Fallo ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: 1128111 Prothonotario Certifico que la siguiente direccion es la del defendido/a sigun indicada en el certificado de residencia: KONSTANTINOS PANAGAKIS 47 SHERWOOD CIRCLE ENOLA, PA 17025-1838 Abogado del Demandante Rule 236(a) (2) Proth. -78 TWO BEER GUYS, LLC, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BRUCE DOUPE and NO. SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, , Defendants TO: KONSTANTINOS PANAGAKIS, Defendant You are hereby notified that on 1.31-11 , judgment by confession was entered against you in the sum of $18,806.05, in the above-captioned case. Date: )-3/-l f othonotary 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 32 South Bedford Street Carlisle, PA 17103 1-800-990-9108 (717) 249-3166 I hereby certify that the following is the address of the defendant stated in the certificate of residence: 47 Sherwood Circle Enola, Pennsylvania 17025-1838 4 Shelly J. unkel, Esquire Attorney for Plaintiff TWO BEER GUYS, LLC, PLAINTIFF VS BRUCE DOUPE AND SHANNON DOUPE, HUSBAND AND WIFE and KONSTANTINOS PANAGAKIS AND KRISTIN PANAGAKIS, HUSBAND AND WIFE DEFENDANT IN THE COURT OF COMMON PLEAS OF CIJPBERLANDCOUNTY, PENNSYLVANIA NO. ;U51 l - / d ? S CIVIL ACTION - To SHANNONDOUPE, Defendant(s) You are hereby notified that on 1128111, the following E] Order ? Decree ® Judgment has been entered against you in the above captioned case. Money Judgment in the amount of $18,806 05 DATE: 1 -3141 Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: SHANNON DOUPE 960 ALEXANDER SPRING ROAD CARLISLE, PA 17015-7909 A BRUCE DOUPE, Defendido/a Defendidos/as Por este medio se le esta notificando que el de del el/la siguiente ? Orden ? Decreto ® Fallo ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: 1128111 Certifico que la siguiente direccion es la del defendido/a sigun indicada en el certificado de residencia: SHANNON DOUPE 960 ALEXANDER SPRING ROAD CARLISLE, PA 17015-7909 Abogado del Demandante Rule 236(a) (2) Proth. - 78 TWO BEER GUYS, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW C? Vi T? 1 BRUCE DOUPE and NO. 0201409S SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, Defendants TO: SHANNON DOUPE, Defendant You are hereby notified that on ? - 31-11 , judgment by confession was entered against you in the sum of $18,806.05, in the above-captioned case. Date: othonotary 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 32 South Bedford Street Carlisle, PA 17103 1-800-990-9108 (717) 249-3166 I hereby certify that the following is the address of the defendant stated in the certificate of residence: 960 Alexander Spring Road Carlisle, Pennsylvania 17015-7909 Shelly J. K el, Esquire Attorney for Plaintiff TWO BEER GUYS, LL C, IN THE COURT OF COMMON PLEAS OF CUMBERLAWOUNTY, PENNSYLVANIA PLAINTIFF VS BRUCE DOUPE AND SHANNONDOUPE, HUSBAND AND WIFE and KONSTANTINOS PANAGAKIS AND KRISTIN PANAGAKIS,HUSBAND AND WIFE DEFENDANT NO. CIVIL ACTION - To KRISTIN PANAGAKIS, Defendant(s) You are hereby notified that on 1128111, the following El Order El Decree ® Judgment has been entered against you in the above captioned case. Money Judgment in the amount of $18,806.05 DATE: 3 /:a I hereby certify that the name and address of the proper person(§) to receive this notice is: KRISTIN PANAGAKIS 47 SHERWOOD CIRCLE ENOLA, PA 17025-1838 A KONSTANTINOS PANAGAKIS, Defendido/a Defendidos/as Por este medio se le esta notificando que el de del el/la siguiente ? Orden ? Decreto ® Fallo ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: 1128111 Prothonotario Certifico que la siguiente direccion es la del defendido/a sigun indicada en el certificado de residencia: KRISTIN PANAGAKIS 47 SHERWOOD CIRCLE ENOLA, PA 17025-1838 Abogado del Demandante Rule 236(a) (2) Proth. -7s TWO BEER GUYS, LLC, Plaintiff V. BRUCE DOUPE and . SHANNON DOUPE, husband and wife KONSTANTINOS PANAGAKIS and KRISTIN PANAGAKIS, husband and Wife, Defendants TO: KRISTIN PANAGAKIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. You are hereby notified that on 1-3t- (I , judgment by confession was entered against you in the sum of $18,806.05, in the above-captioned case. Date: onotary 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 32 South Bedford Street Carlisle, PA 17103 1-800-990-9108 (717) 249-3166 I hereby certify that the following is the address of the defendant stated in the certificate of residence: 47 Sherwood Circle Enola, Pennsylvania 17025-1838 Shelly J. el, Esquire Attorney for Plaintiff