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Home My WebLink About01-2834 .-~-~_.--c~:::-c-..,~--,-.-_.._-- - 1111111111111111111111111111111111111111111111111111111111111111111111 2880114-40-2 PARTIES 90265 HAPL ~~~=rr~~-~~~~--- FINANCING STATEMENT - --~---,-- t;'" ~. Uniform Commercial Code Form UCC.1 Debtor name (last name first If Individual) and mailing address: IMPORTANT -Please read instructions on BUSLER, KELL Y __~ reverse side of p.ge 4 before CO'1'pI8ti~,\t'i:(',f' ~__ 3l1t-WESTVIEW DRIVE Filing No. (stamped by filing officer): O~~Ji~Fi1ing9ffice:~tahi?ed,6~~J4~~) 1\4ECHANICSBURG, PA 17055 2,11-18-2-801 !0\ - -:1S31 ~ 01, """ ,," . 1 ~ 'i Q pq t:::9 \ ,. Debtor Name (last name first if individual) and mailing address: STITCHWORKS 301 WESTVIEW DRIVE MECHANICSBURG, PA 17055 rIJ I'''''' I'IT'( _.,.<'...;Vl"ll n"''',l;' !..:'\(': ,.,f:\\{1A I'CJ,..:\\,-1 L.", " , " This Financing Statement is presented fot filing pursuant to 111$ Uniform CommerCial Code, and is lo be flfe<j with the (check applk:able box): o Secretary of the commonwealthC L ,,_[ 1 ~prothonotaryof lA Y\-)f~ Ct,fl\~~__County o real estate records of County Debtor name (last name firSt if individual) and mailing address: 6 'b Number of Additional Sheets (if any): Optional Special Identification (Max. 10 Characters): COLLATERAL Identity collateral by item and/or type: TAJIMA EMBROIDERY MACHINE MOOEL #TMFX11 C1502i450WCT, SIN U1041, EXPRESS SOFTWARE, SiN PM90391, INCLUDES ALL ACCESSORIES, ATTACHMENTS AND ANY REPLACEMENTS THEREOF 2880114 , Secured Party(les) names(s) (last name first If individual) and lOA' UE""tv 11110ro01lnlonn.llon: H ,I-'I LEfaslng 1...;0., Inc. 200 Wireless Boulevard Hauppauge, NY 11788 ln~eet1 Assignee(s) of Secured Party name(s) (last name first if individual) and address for security interest information: ABB Business Finance 1 Research Drive Suite 401 B Westboro, MA01581 2 " ~eclal Type$ of Parties (check If applicable): U The tenns"Deblot" ~n"Cl "Secured Party" mean "Les$ee" and "Lessor," respectively. o The terms .Debtor" and "Secured Party" mean "Consignee" and "Consignor:respeClively. o (Checkonlylfdeslred)Productsofthecollateralarea\socovered. , SECURED PARTY SIGNATURE(S) n realed r$al estate,rtappllcable:Tllecollal4:lnllla,OrlnCIUCeS{CneCk appropl'\atebox{es)}. crops growing or to be grown on- .0 goodswhlchareorarelobecomeflxtufflson- o minerals or the "ke (Including oil and gas) as extracted 01"1- ..0 .a9Counts resultif'lg from the sale of mlnamls or tile lIke (lnc\uding oil and gas) 01\ the wellhead or mineheadon- o Debtor is a Tl1lInsmltting UUUty. 3 This statement is filed witll OI'Ily the Sewrecl Party's signature to perfel;t a secul'lty InterElStln collateral {checl<. app\lcablebox(es))- a.D aCQUired after a change of name, identity or corporate structure of the Debtor. b.O astowlllChltlefl"nghas\apaed c,alreadysublecttoaseCUlityinterestinatlothercountylnPennsytvania o when the collateral was moved to tIIis county o when the Debtor's residence or place of busIness was moved to Ihiacounty. d_alreal1ysut)jecttoasecuril)'\nterestinanotherjurtsdlctlon_ o wilen tile collateral was moved to Pennsylvania o when the Debtor's locatlof\ was mOV\'ld to Pennsylvania. the following real estate; Street Addre$s; Described at: Book of (check one)D Deeds 0 Mortgages. at Page{s) County. Unifonn Parcel Identifier for o Described on Additional Sheet. Name of record owner {required only If no debtor has an Interest of record): DEBTOR SIGNATURE(S) Debtor Slgnature(s): BUSLER, KELLY SIGNING FOR All e,D wlliCh ls proceecla of the collateral descrtbed In bloCk 9,ln which a secul'lty Interestwaa previously perfected (also describe proceeds ifl block 9, If purchased with cash proceeds and not adequately describeo' on the 0l'\gina(flnanc1ng statement). .,. IW-1 rJ t:: , ]r)~, 6-z tl~ Attorney-In-fact 1b ~4 C'>>\A. RETURN RECEIPT TO: Secured Party Slgnature(s) (required only if box(es) is checked above}: UCC Direct Services P,O, Box 29071 Glendale CA Phone "~~ Attorney-in-fact CAROLE WALSH 4 (800) 331-3282 \~~-9071 F" (818) 662-4141 P",CJS.~~1'~'S!C~il'" PO e,,"071,GI"'d'~ CA91209-0071 T" {80O)33""82 FILING OFFICE ORIGINAL ~ +r 111397 STANDARD FORM - FORM UCC-1 {1-89) Approved by SecretaI)' of Commonwealth of Pennsylvania NATHAN C. WOLF, ESQUIRE AlTORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY MOTION FOR RECONSIDERATION NOW COMES counsel of record for Plaintiff Victoria E. Greeger, Nathan C Wolf, Esquire, and respectfully submits the following motion for reconsideration, pursuant to PaRCP. 1701, and in support thereof, avers as follows: 1. Plaintiff, Victoria E. Greeger, is an adult individual who is a resident of the State of Pennsylvania, and whose last known address was 175 East North Street Guiisle, Pennsylvania 17013. 2. The undersigned filed a motion to withdraw as counsel on or about June 29, 2006. 3. This Honorable Court issued an order denying the relief requested in said motion by Order dated July 5, 2006. (A true and correct copy is attached hereto as Exhibit A) 4. The undersigned respectfully requests that the Court reconsider its Order on the following grounds: a. The Plaintiff stated to counsel that she did not want him to represent her at the hearing because she could not afford his services. b. The Plaintiff infonned counsel that she would, if necessary, represent herself in the proceedings. c. The Plaintiff promised counsel that she would contact him to confirm this position following her release from the hospital which occurred on or about ]\U1e 23,2006. d. Counsel has attempted to contact Plaintiff approximately five times prior to ]\U1e 21,2006 to communicate with her concerning the preparntion of the required pretrial memorandum with no response. e. Counsel has attempted to contact Plaintiff at least four times since her release from the hospital on or about ]\U1e 23, 2006 concerning his representation of Plaintiff, with no response. f. Counsel has communicated with Plaintiff's mother requesting her assistance in contacting Plaintiff and Plaintiff's mother has represented that Plaintiff was aware of counsel's attempts and that Plaintiff did not see a need to respond to counsel. 5. The \Uldersigned has, moreover, informed Plaintiff that without appropriate compensation, she had breached the fee agreement between plaintiff and counsel, and that he would seek leave to withdraw from the case. 6. The \Uldersigned believes and therefore avers that no prejudice would be suffered by his client if the instant motion is granted, and that this Court should grant the relief requested in accordance with his client's wishes. 7. The \Uldersigned believes and therefore avers that the Court's granting of the instant motion would not delay the proceedings scheduled before the Court. 8. The \Uldersigned counsel contacted Michael J. Whare, Esquire, counsel for Defendant, for concurrence in the filing of this motion and such concurrence was given. WHEREFORE, the movant, Nathan C. Wolf, Esquire, respectfully prays that this Court reconsider its prior denial of leave to withdraw from his representation of Plaintiff, Victoria E. Greeger, and to grant said relief and permit counsel to withdraw, and to grant any further relief that the Court deems appropriate. Respectfully submitted, WOLF&W F Dated: July ..:J...., 2006 By: , Esquire Street 17013 S me Court 1.0. No. 87380 (717) 241-4436 Attorney for Plaintiff VERIFICATION I, the undersigned, do hereby verify that the facts set forth in this Motion are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsification to authorities. Dated: July -1-, 2006 RECEIVED JUl 061006 VICTORIA E, GREEGER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2001-2824 CIVIL V. BRETT A. GREEGER, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 5th day of July, 2006, upon consideration of the Motion for Leave to Withdraw as Counsel filed by Nathan C. Wolf, Esquire, and the Court noting that a custody hearing which was continued at the Plaintiff's request is scheduled for Tuesday, July 11,2006 at 1:30 p.m., IT IS HEREBY ORDERED AND DIRECTED that the Motion of Nathan C, Wolf, Esquire is DENIED at this time. The Motion will be reconsidered upon conclusion of the custody hearing scheduled for July 11, 2006. By the Court, Victoria E. Greeger Plaintiff Nathan C. Wolf, Esquire Attorney for Plaintiff Michael J, Whare, Esquire Attorney for Defendant bas NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARliSLE PA 17013 (717) 241-4436 VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C Wolf, Esquire, hereby certify that I mailed a true and correct copy of the foregoing Motion for Reconsideration of Motion for Leave to Withdraw as CoWlSel to the be1ow- listed persons by U.S. Mail addressed as follows: Victoria E. Greeger 175 East North Street Carlisle, PA 17013 MichaelJ. Whare, Esquire Rominger & Whare 155 South Hanover Street Carlisle, PA 17013 Counsel for Defendant Dated: July L 2006 . olf, Esquire -', o c:: l'--> ,.......:; , c~ D -n --1 :1";;D n'r-- ~~, r.:;:::. <- , I j.... ~? c.) CO :l:J; .-<.