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HomeMy WebLinkAbout02-0244IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ClVlL ACTION WAYPOINT BANK F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff VS. KEITH L. PLASTERER JAMIE L. PLASTERER Defendants Confession of Judgment CONFESSION OF JUDGMENT Pursuant to the authority contained in the Warrant of Attorney, a copy of which is attached hereto, I appear for the above Defendants and confess judgment in favor of the Plaintiff and against the Defendant, as follows: Principal Balance Interest through 1/11/02 Late Charges Reasonable Attorneys Fees (10%) $47,290.56 $ 2,520.83 $ 519.17 $ 4,729.06 Total $55,059.62 Judgment entered as above. By' Benjamin/:. Riggs, Jr. 0 '(d" Attorney for Defendant 235 North Second Street P.O. Box 1711 Harrisburg, PA 17105 Phone: (717) 815-4518 I.D. No. 72030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION WAYPOINT BANK F/KJA YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff VS. KEITH L. PLASTERER JAMIE L. PLASTERER Defendants Confession of Judgment COMPLAINT AND NOW, to wit, this //7_.~ day of January, 2002, comes Waypoint Bank, Plaintiff, by and through its attorney, Benjamin F. Riggs, Jr., and files this Complaint upon a cause of action whereof the following is a statement: 1. The Plaintiff is Waypoint Bank, a corporation organized and existing under the laws of the United States of America, and it is registered to do business in Pennsylvania, with offices for the purpose of doing business at 235 North Second Street, Harrisburg, Pennsylvania. 2. The Defendants, Keith L. Plasterer and Jamie L. Plasterer whose principal address is 36 Kelly Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. That attached hereto and incorporated herein by reference thereto is a copy of the original instrument executed by the Defendant authorizing confession of judgment (Promissory Note dated December 28, 1999). a "consumer credit transaction" The attached instrument has not been assigned. That the judgment to be entered does not involve a loan defined as in accordance with Annex ^. to Title 231, 6. That judgment has not been entered on the attached instrument in any jurisdiction. 7. The attached instrument provides for confession of judgment against the Defendant, at the Plaintiff's option. Plaintiff has exercised its option to confess judgment pursuant to the terms of the instrument for an amount which the Defendant may become liable. Plaintiff as follows, as of January 11, 2002: Principal Balance Interest through 1/11/02 Late Charges Reasonable Attorneys Fees (10%) Total attached instrument. WHEREFORE, Plaintiff Waypoint Bank demands judgment against the Defendant in the total sum as authorized by the Warrant appearing in the By: Benjamin r~. Riggs, Attorney for Plaintiff 235 North Second Street P.O. Box 1711 Harrisburg, PA 17105~1711 Phone: (717) 815-4518 I.D. No. 72030 As a consequence of the foregoing, the Defendant is liable to the $47,290.56 $ 2,52O.83 $ 519.17 $ 4,729.O6 $55,059.62 Chapter 2950, Rule 2951(a)(2). PROMISSORY NOTE ~Borrower: Kelth L. Plasterer Jamle L. Plasterer 36 Kelly Drive Carilsta, PA 17013 Lender: Harris Savings Bank 234 N. Second Street P O Box 1711 Harrisburg, PA 17105 ~Principal Amount: $49,588.75 Initial Rate: 10.500% Date of Note: December 28, 1999 ~PROMISE TO PAY. Kelth L. Plasterer and Jamle L. Plasterer ("Borrower") promise to pay to Harris Savings Bank ("Lender"), or order, In lawful ~money of the Unlled States of America, the principal amount of Forty Nine Thousand Five Hundred Eighty Eight & 75/100 Dollars ($49,~88.75), ~:togsther with Interest on Ihe unpaid principal balance from December 28, 1999, until paid In full. PAYMENT. Subject to any payment changes rseultlng from changes in the Index, Borrower will pay this loan In 59 principal payments of $2o6.62 each and one final principal and Interest payment of $37,736.31. Borrower's first principal payment Is due February 1, 2000, and all subsequent principal payments ere due on the same day of each month after that. In addition, Borrower will pay regular monthly payments of all accrued unpaid interest due as of each payment date. Borrower's first interest payment ta due February 1, 2000, and all sub__~,_,qeant interest payments ere due on the same day of each month after that. Borrower's final payment due January 1, 2005, will be for ali principal end~accrund Interest not yet paid. The annual interest rate for this Note is computed on a 365/360 basis; that is, by applying the ratio of the annual interest rate over a year of 360 days, multiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance is outstanding. Borrower will pay Lender at Lender's address shown above or at such other place as Lender may designate in writing. Unless otherwise agreed or required by applicable law, payments will be applied first to accrued unpaid interest, then to principal, end any remaining amount to any unpaid collection costs and late charges. -VARIABLE INTEREST RATE. The interest rate on this Note is subject to change from time to time based on changes in an independent index which is the Prime Rate as published in the Money Rate Section of the Wall Street Journal. If a range of rates is published then the higher of the rates will be used. (the "Index"). The Index is not necessarily the lowest rate charged by Lender on its loans. If the Index becomes unavellabla during the term of this loan, Lender may designate a substitute index after notice to Borrower. Lender will tell Borrower the current Index rate upon Borrower's request. Borrower understands that Lender may make loans based on other rates as well. The interest rate change will not occur more often than each Day. The Index currently is 8.600% par annum. The interest rate to be applied to the unpaid principal balance of Ihta Note will be at a rate of 2.000 .percentage paints over the Index, resulting In an Initial rate of 10.600% par annum. NOTICE: Under no circumstances will the interest rate on this Note be more than the maximum rate allowed by applioabla law. 'PREPAYMENT. Borrower may pay all or a portion of the amount owed earlier than it is due. Early payments will not, unless agreed to by Lender in balanceWriting' relievedue andB°rr°Wermay result°f Borrower'Sin Borrower°bligati°nmaking fewert° continUepayments.to make payments under the payment schedula. Rather, they will reduce the principal LATE CHARGE. If a payment is 15 days or more late, Borrower will be charged 5.000% of the regularly scheduled payment or $10.00, whichever Is greater. - DEFAULT. Borrower will be in default if any of the following happens: (al Borrower fails to make any payment when due. (b) Borrower breaks any promise Borrower has made to Lender, or Borrower fails to comply with or to perform when due any other term, obligation, covenant, or condition contained in this Note or any agreement related to this Note, or in any other agreement or loan Borrower has with Lender. (c) Any representation or statement made or f[Jrnished to Lender by Borrower or on Borrower's behalf is false or misleading in any material respect either now or at the time made or furnished. (d) Borrower dies or becomes insolvent, a receiver is appointed for any pad of Borrower's property, Borrower makes an assignment for the benefit of creditors, or any proceeding is commenced either by Borrower or against Borrower under any bankruptcy or insolvency laws. (el Any creditor tries to take any of Borrower's property on or in which Lender has a lien or security interest. This includes a garnishment of any of Borrower's accounts with Lender. (fl Any of the events described in this default section occurs with respect to any guarantor of this Note. (gl A materiel adverse change occurs in Borrower's financial condition, or Lender believes the prospect of payment or performance of the Indebtedness is impaired. If any default, olher than a default in payment, is curable and if Borrower has not been given a notice of a breach of the same provision of this Note within the preceding twelve (12) months, it may be cured (end no event of default will have occurred) if Borrower, after receiving whiten notice from Lender demanding cure of such default: (al cures the default within fifteen (15) days; or (b) if the cure requires more than fifteen (15) days, immediately initiates steps which Lender deems in Lender's sole discretion to be sufficient to cure the default and thereafter continues and completes all reasonable and necessary steps sufficient to produce compliance as soon as reasonably practical. · LENDER'S RIGHTS. Upon 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. Upon default, including failure to pay upon final maturity, Lender, at its option, may also, if permitted under applicable iew, increase the variable interest rate on this Note to 4.000 percentage points over the Index. The interest rate will not exceed the maximum rate permitted by applicabla law. Lender may hire or pay someone else to help collect this Note if Borrower does not pay. Borrower also will pay Lender that amount. This includes, subject to any limits under applicable law, Lender's altornays' fees and Lender's legal expenses whether or not there is a lawsuit, including attorneys' fees and legel expenses for bankruptcy proceedings (including efforts to modify or vacate any automatic stay or injunction), appeals, and any anticipated post-judgment collection services. If not prohibited by applicable law, Borrower also will pay any court costs, in addition to all other sums provided by law. If judgment is entered in connection with this Note, interest will continue to accrue on this Note after judgment at the interest rate applicable to this Note st the time judgment is entered. This Note has been delivered to Lender and accepted by Lender In the Commonwealth of Pennaylvesla. If there Is a lawsuit, Borrower agrees upon Lender's request to submit to the jurisdiction of the cou~te of Dsuphin County, the Commoowselth of Pennsylvania. This Note shall be governed by and construed In accordance with the laws of the Commonwealth of Pennsylvonla. RIGHT OF SE"TOFF. Borrower grants to Lender a contractual security interest in, and hereby assigns, conveys, delivers, pledges, and transfers to Lender all Borrower's dght, title and interest in and to, Borrower's accounts with Lender (whether checking, savings, or some other account), including without limitation all accounts held jointly with someone else and all accounts Borrower may open in the future, excluding however ail IRA and Keogh accounts, and all trust accounts for which the grant of a security interest would be prohibited by law. Borrower authorizes Lender, to the extent permitted by applicable law, to charge or setoff all sums owing on this Note against any and all such accounts. COLLATERAL. This Note is secured by a Mortgage dated December 28, 1999, to Lender on real property located in Cumberland County, 12-28--199S PROMISSORY NOTE Page 2 Loan No 8876001201 (Continued) Commonwealth of Pennsylvania, ell the terms and conditions of which are hereby incorporated and made a part of this Note. SECURITY. All collateral (as herein defined) is secudty for this Note and any renewals, extensions and modifications thereof, and the payment, performance and discharge of all other present or future indebtedness, obligations and undertakings (whether individual, joint, several, direct, contingent or otherwise) of the Borrower to or for the benefit of Lender, whether arising directly to Lender under this Note or under any other agreement, promissory note or undertakings now existing or hereinafter entered into by the Borrower to Lender. The term "Collateral" includes all tangible and intangible properfy (ii described in any mortgage, assignment or any other security document separately executed in favor of Lender pursuant to this Note, and (ii) in which a security interest has been granted to Lender pursuant to this Note. GENERAL PROVISIONS. Lender may delay or forgo enforcing any of its dghts or remedies under this Note without losing them. Borrower and any other person who signs, guarantees or endorses this Note, to the extent allowed by law, waive presentment, demand for payment, protest and notice of dishonor. Upon any change in the terms of this Note, and unless otherwise expressly stated in writing, no party who signs this Note, whether as maker, guarantor, accommodation maker or endorser, shall be released from liability. All such parties.agree that Lender may renew or extend (repeatedly and for any length of time) this loan, or release any psdy or guarantor or collaterat; or impair, fail to realize upon or perfect Lender's security interest in the collateral; and take any other action deemed necessary by Lender wffhout the consent of or notice to anyone. All such parties also agree that Lender may modify this loan without the consent of or notice to anyone other than the party with whom the modification is made. The obligations under this Note are joint and several. If any podion of this Note is for any reason determined to be unenforceable, it will not affect the enforceability of any other provisions of this Note. CONFESSION OF JUDGMENT. BORROWER HEREBY IRREVOCABLY AUTHORIZES AND EMPOWERS ANY A'FI'ORNEY OR THE PROTHONOTARY OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY TIME FOR BORROWER AFTER A DEFAULT UNDER THIS NOTE, AND WITH OR WITHOUT COMPLAINT FILED, AS OF ANY TERM, CONFESS OR ENTER JUDGMENT AGAINST BORROWER FOR THE ENTIRE PRINCIPAL BALANCE OF THIS NOTE, ALL ACCRUED INTEREST, LATE CHARGES, AND ANY AND ALL AMOUNTS EXPENDED OR ADVANCED BY LENDER RELATING TO ANY COLLATERAL SECURING THIB NOTE TOGETHER WITH INTEREST ON SUCH AMOUNTS, TOGETHER WITH COSTS OF SUIT, AND AN A'CI'ORNEY'S COMMISSION OF TEN PERCENT (10%) OF THE UNPAID PRINCIPAL BALANCE AND ACCRUED INTEREST FOR COLLECTION, BUT IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS ($500) ON WHICH JUDGMENT OR JUDGMENTS ONE OR MORE EXECUTIONS MAY ISSUE IMMEDIATELY; AND FOR SO DOING, THIB NOTE OR A COPY OF THIS ' NOTE VERIFIED BY AFFIDAVIT SHALL BE SUFFICIENT WARRANT. THE AUTHORITY GRANTED IN THIB NOTE TO CONFESS JUDGMENT AGAINST BORROWER SHALL NOT BE EXHAUsiI::D BY ANY EXERCISE OF THAT AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND AT ALL TIMES UNTIL PAYMENT IN FULL OF ALL AMOUNTS DUE UNDER THIS NOTE. BORROWER HEREBY WAIVES ANY RIGHT BORROWER .MAY HAVE TO NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF JUDGMENT, EXCEPT ANY NOTICE AND/OR -HEARING REQUIRED UNDER APPLICABLE LAW WiTH RESPECT TO EXECUTION OF THE JUDGMENT, AND STATES THAT EiTHER A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THIS CONFESSION OF JUDGMENT PROVISION TO BORROWER'S A'I"I~-NTION OR BORROWER HAS BEEN REPRESENTED BY INDEPENDENT LEGAL COUNSEL. THE LIEN ARISING FROM ANY JUDGMENT CONFESSED OR ENTERED PURSUANT TO THE FOREGOING AUTHORITY SHALL NOT EXTEND TO ANY OF BORROWER'S RESIDENTIAL REAL PROPERTY AS THAT TERM IS DEFINED IN THE PENNSYLVANIA ACT OF JANUARY 30, 1974 (PA. LAWS 13, NO. 6), REFERRED TO AS THE LOAN INTEREST AND PROTECTION LAW, AS AMENDED, AND THE HOLDER OF ANY JUDGMENT CONFESSED OR ENTERED PURSUANT TO THE FORGOING AUTHORITY SHALL NOT, IN ENFORCEMENT OF ANY SUCH JUDGMENT, EXECUTE, LEVY OR OTHERWISE PROCEED AGAINST ANY SUCH RESIDENTIAL REAL PROPERTY; PROVIDED, HOWEVER, THAT THE LIEN OF SUCH JUDGMENT SHALL EXTEND TO SUCH RESIDENTIAL REAL PROPERTY AND THAT THE HOLDER THEREOF SHALL BE PERMI'I"'~ ~-D TO EXECUTE, LEVY OR PROCEED AGAINST SUCH RESIDENTIAL REAL PROPERTY FROM AND A~-I~-R THE ENTRY OF A JUDGMENT AS CONTEMPLATED BY SECTION 407 OF SUCH LOAN INTEREST AND PROTECTION LAW AND RULES 2981 TO 2986 OF THE PENNSYLVANIA RULES OF CIVIL PROCEDURE, OR SUCCESSOR OR SIMILAR STATUTES AND RULES. NO LIMiTATION OF LIEN OR ANY EXECUTION, LEVY OR OTHER ENFORCEMENT CONTAINED IN THE IMMEDIATELY PRECEDING SENTENCE SHALL APPLY WITH RESPECT TO ANY JUDGMENT OBTAINED OTHER THAN BY THE FOREGOING AUTHORITY TO CONFESS OR ENTER JUDGMENT. PRIOR TO SIGNING THIS NOTE, EACH BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE, INCLUDING THE VARIABLE INTEREST RATE PROVISIONS. EACH BORROWER AGREES TO THE TERMS OF THE NOTE AND ACKNOWLEDGES RECEIPT OF A COMPLETED COPY OF THE NOTE. THIS NOTE HAS BEEN SIGNED AND SEALED BY THE UNDERSIGNED. BORROWER: ':':' ............. ================================================================================================================= ' .~'.!~!i Xi::!i ~"~ :'?""'""~:'~'~ ''~' ~::i~::::::::~::~:: ..~.~:~'..::..:i :::~.~.~:~,..,..->>x:..-~ ~.~..x~.. ×,:.x~.?.>:~.:.>......:.:~:.?.-<. Kelth L Plasterer ~fl~le L. Plasterer LENDER: variab i~rFlr i~Bn dmm~O~+ ~ rC~t 'err e s t. LASER PRO, ReD. U.S. Pat. & T.M. Off., Vet. 3.'27 (c) 1 ggg CFi Pr=Services, Inc. All rights reservecL IPA-O2O PLASTER. L N C2.OVL] DlSCLOS~E FOR CONFESSION OF-,~IIDGMENT Keith L. Plasterer Lender: Hatr~ SavlngSBank Jamle L. Plasterer 36 Kelly Drive 234 N. ~econd Street Carli,de, PA 17013 P O Box 1711 HarriSbUrg, PA 1710S DISCLOSURE FOR CONFESSION OF JUDGMENT IAME~ECUTING, THIS ~ DAY OF ~/~// . 19 ~, A PROMISSORY NOTE FOR $49,,..75 Oi~,GATiNG ME TO REPAY THAT AMOUNT. 'A. I UNDERSTAND TI'IRT THE NOTE CONTAINS A CONFESSION OF dUDGMENT PROVISION THAT WOULD PERMIT LENDER TO ENTER JUDGMENT AGAINST ME IN COURT, AFTER A DEFAULT ON THE NOTE, WITHOUT ADVANCE NOTICE TO ~ AND WITHOUT OFFERING ME AN OPPORTUNITY TO DEFEND AGAINST THE ENTRY OF JUDGMENT. IN EXECUTING THE NOTE, BEING FULLy AWARE OF MY RIGHTS TO ADVANCE NOTICE AND TO A HEARING TO CONTEST THE VALIDITY OF ANY JUDGMENT OR OTHER CLAIMS THAT LENDER MAY ASSERT AGAINST ME UNDER THE NOTE, I AM KNOWINGLY, INTFI I IGENTLY, AND VOLUNTARILY WAIVING THESE RIGHTS, INCLUDING ANy RIGHT TO ADVANCE NOTICE OF THE ENTRY OF JUDGMENT, AND I EXPRESSLY AGREE AND CONSENT TO LENOER'S · ENTERING JUDGMENT AGAINST ME BY CONFESSION AS PROVIDED FOR IN THE CONFESSION OF dUDGMENT PROVISION. INITIALS: ::::::::::::::::::::::::::::::::::::::::: :::::::::::::::::::::::::::::::::::::::::::::::::: B. I FURTHER UNDERSTAND THAT IN ADDITION TO GIVING LENDER THE RIGHT TO ENTER JUDGMENT AGAINST ME WITHOUT ADVANCE NOTICE OR A HEARING, THE CONFESSION OF JUDGMENT PROVISION IN THE NOTE ALSO CONTAINS LANGUAGE THAT WOULD PERMIT LENDER, AFTER ENTRY OF JUDGMENT, TO EXECUTE ON THE JUDGMENT BY FORECLOSING UPON, ATTACHING, LEVYING ON, TAKING POSSESSION OF OR OTHERWISE SEIZING MY PROPERTY, IN FULL OR PARTIAL PAYMENT OF THE JUDGMENT. HOWEVER, LENDER MUST PROVIDE NOTICE TO ME UNDER APPLICABLE LAW IN EXECUTING ANY CONFESSED JUDGMENT. IN EXECUTING THE NOTE, BEING FULLY AWARE OF MY RIGHTS TO ADVANCE NOTICE AND A HEARING Ai~feR JUDGMENT IS ENTERED ' ' AND BEFORE EXECUTION ON THE JUDGMENT, I AM KNOWINGLY, INTFI I IGENTLY AND VOLUNTARILY WAIVING THESE RIGHTS, AND I EXPRESSLY AGREE AND CONSENT TO LENDER'S EXECUTING ON THE JUDGMENT, IN ANY MANNER PERMITTED BY APPLICABLE C. AFTER HAVING READ AND DETERMINED WHICH OF THE FOLLOWING STATEMENTS ARE APPLICABLE, AND BY PLACING MY INITIALS NEXT TO EACH STATEMENT WHICH APPLIES, I REPRESENT THAT: INITIALS 1. I WAS REPRESENTED BY MY OWN INDEPENDENT LEGAL COUNSEL IN CONNECTION WITH THE NOTE. 2. A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THE CONFESSION OF JUDGMENT PROVISION IN THE NOTE TO MY ATTENTION. D. I CERTIFY THAT MY ANNUAL INCOME EXCEEDS $10,000; THAT THE BLANKS IN THIS DISCLOSURE WERE FILLED IN WHEN I INITIALED AND SIGNED IT; AND THAT I RECEIVED A COPY AT THE TIME OF SIGNING. THIS DISCLOSURE HAS BEEN SIGNED AND SEALED BY THE UNDERSIGNED. ....................................................... X ~:~:;.,,,..,.. ~ ' ' (SEAL) Kellh L. Plasterer LASER PRO, Reg. U.S. Pat. & T.M. Off., Var. 3.27 (c) 1999 CFI ProServlcea, Inc. All rlgh ts reserved. [PA-D30 PLASTER.L N C2.OVL] ONFESSION OF JUDGMENT =orrower: Kelth L. plasterer Jamle L. plasterer ~ Kelly Drive Carlisle, PA 17013 Lender: Herds Savings Bank 234 N. Second Street P 0 Box 1711 Harrisburg, PA 17105 DISCLOSURE FOR CONFESSION OF JUDGMENT ~ME TO REPAY THAT AMOUNT. ;A. I UND~ST~D THAT THE NOTE CONTAINS A coNFESSION OF JUDGMENT PROVISION T~T WO~D P~MIT ~D~ TO ENT~ J~GMENT AGAINST ME IN COURT, ~ A D~A~T ON THE NOTE, WI~ ~VANCE NOTICE TO ME AND WlT~ OFFERING -ME AN oP~RTUNI~ TO D~D AGAINST ~E ENTRY OF JUDGM~T. IN ~EC~ING THE NOTE, BEING F~Y AW~E OF MY RIG'S TO ADVANCE NOTICE AND TO A H~ING TO CONTEST ~E V~IDI~ OF ~Y JUDGMENT OR OTH~ ~IMS ~AT ~D~ MAY ASSERT AGAINST ME UND~ THE NOTE, I AM KNOWINGLY, INT~IGEN~Y, AND V~UNT~ILY WAIVING ~ESE RIG'S, IN~UDING ~Y RIGHT TO ~VANCE NOTICE OF TH~ ~TRY OF JUDGM~T, ~D I ~PRES~Y AGR~ ~D CONSE~ TO LEN~R'S ~ING JUDGMENT AGAINST ME BY CONFESSION AS PROVlD~ FOR IN THE CONFESSION OF ~GM~T pROvISION- INITI~S: B. I FURTH~ UND~STAND T~T IN ADDITION TO GIVING LEND~ THE RIG~ TO ENT~ J~GM~T AGAINST ME WlT~ A~ANCE NOTICE OR A H~ING, ~E CONFESSION OF JUDGM~T PROVISION IN THE NOTE ~ CONTAINS ~GUAGE ~AT wO~D PERMIT L~DER, A~ER ~TRY OF JUDGME~, TO ~EC~E ON THE JUDGM~T BY FORE~OSING U~N, A~ACHING, L~ING ON, T~ING ~SSESSION OF OR OTH~WI~E SEIZING MY PROPERS, IN F~ OR P~TI~ PAYM~ OF THE JUDGM~T. ~w~ER, LENDER MUST PROVIDE NOTICE TO ME UNDER AP~IC~E ~W IN ~EC~ING ANY CON~SSED J~GMENT. IN *~Ec~ING THE NOTE, BEING F~Y AW~E OF MY RIG'S TO ADVICE NOTICE AND A H~RING ~ JUDGM~T IS ENTERED .AND BEFORE ~EC~ION ON THE JUDGMENT, I AM KNOWINGLY, INTm ~ ~G~Y ~D V~UNTARILY WAIVING ~ESE RIG'S, ~D I .~PRES~Y AGR~ AND CONSE~ TO L~DER'~ ~EC~ING ON THE JUDGM~T, IN ANY M~NER P~MI~D BY AP~IC~E C. A~ HAVING R~D AND D~MINED wHICH OF THE F~OWlNG STATEMENTS ~E ~IC~E, AND BY ~ClNG MY INITI~S N~T TO ~CH STATEMENT WHICH ApplES, I R~RES~T ~AT: 1. I WAS REPRES~TED BY MY OWN INoEPEND~T LEG~ COUNS~ IN CONNEXION WI~ ~E NO~. 2. A REPRES~TATIVE OF L~DER SPEclFIc~Y C~ THE CONFESSION OF JUDGMENT PROVISION IN ~E NOTE TO MY A~ENTION. D. I C~TI~ T~T MY ~NU~ INCOME ~C~DS $10,~; THAT THE ~KS IN THIS DIS~OSURE W~E FI~D IN WHEN I INITI~D ~D SIGNED IT; AND ~AT I RECEIVEO A COPY AT THE TIME OF SIGNING. ~lS DISCLOSURE HAS BE~ SIGNED ~D S~EO BY ~E UND~SIGNED. ~le L. Pl~erer LASER PRO, Re~ U.S. Pat. & T.M. O~ ~., V~. 3.27 (c) 1999 CFI ~u~v~eS, I~. All rights re.erve~. [PA-D30 ~A~R.L N C2.OVLI VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. I further verify that I am a Senior Vice President of WAYPOINT BANK, and that as such, I am authorized to make this Verification on its behalf. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: / -/'-/, WAYP~.,~ By: [__/?-villi',- ~ sH; rn~ rM~i c'~nprnree;~l~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION WAYPOINT BANK F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff VS. KEITH L. PLASTERER JAMIE L. PLASTERER Defendants Confession of Judgment OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise mailing address of the Plaintiff is: P. O. Box 17'11, Harrisburg, Pennsylvania 17105-1711 I hereby certify that the precise mailing address of the Defendants Keith L. Plasterer and Jamie L. Plasterer is: 36 Kelly Drive, Carlisle, Pennsylvania 17013 By: Benjamin F. Rig~s,~--~. Attorney for Plaintiff 235 North Second Street P.O. Box 1711 Harrisburg, PA 17105-1711 Phone: (717) 815-4518 I.D. No. 72030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION WAYPOINT BANK F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff VS. KEITH L. PLASTERER JAMIE L. PLASTERER Defendants No. ~ __3~/~ Confession of Judgment Commonwealth of Pennsylvania County of York Before me, a Notary Public for York County, Pennsylvania, personally appeared Benjamin F. Riggs, Jr., Attorney for the Plaintiff in the above entitled case, who being duly sworn or affirmed according to law deposes and says, that the Defendants above named are not in the military service of the United States of America, that he has personal knowledge that the said Defendants, Keith L. Plasterer and Jamie L. Plasterer's last-known address is 36 Kelly Drive Carlisle, Cumberland County, Pennsylvania 17327. Sworn and subscribed before me this / ¢~day of January, 2002 Notary Public My Commission expires: I No,~,.~S., '1 ~ Sandra M. Aulbach, Notary Public I city of York, York ..Cpunty / J My Commission Expires May 23, Benjamin-F. mRiggs, Attorney for Plaintiff I.D. No. 72030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION WAYPOINT BANK F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff VS. KEITH L. PLASTERER JAMIE L. PLASTERER Defendants Confession of Judgment NOTICE OF FILING JUDGMENT ( ) Notice is hereby given that a judgment in the above-captioned matter has bf~en entered against you in the amount of $ 55,059.62 on the /TP~ day of January, 2002. ( ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. Prothonotary Civil Div. ~./ -~ If you have any questions concerning the above case, please contact the following party: Benjamin F. Riggs, Jr. (hD.#72030) Attorney for the Plaintiff 235 North Second Street P. O. Box 1711 Harrisburg, Pennsylvania 17105-1711 Telephone: (717) 815-4518 (This Notice is given in accordance with Pa.R.C.P. 236.) Notice sent: Keith L, Plasterer Jamie L. Plasterer 36 Kelly Drive Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION WAYPOINT BANK F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff VS. KEITH L. PLASTERER JAMIE L. PLASTERER Defendants Confession of Judgment TO: NOTICE OF DEFENDANT'S RIGHT,~ Keith L. Plasterer Jamie L. Plasterer 36 Kelly Drive Carlisle, PA 17013 A judgment in the amount of $55,059.62 has 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 your. 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 T A JUDGE WITHIN THRITY (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 LAWYEER AT ONCE. IF YOU DO NOT HAVE A LAWYER AND 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 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION WAYPOINT BANK F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff VS. KEITH L. PLASTERER JAMIE L. PLASTERER Defendant No. Confession of Judgment CERTIFICATE OF SERVICE AND NOW, to wit, this.. /~-,//'~'- day of January, 2002, I, Benjamin F. Riggs, Jr., Esquire, attorney for Plaintiff Waypoint Bank of 235 North Second Street, Harrisburg, Pennsylvania, hereby certify that I served a true and correct copy of the Notice of Defendarlt's Rights filed in the above captioned matter by certified, first class, mail, return receipt requested, as well as first class mail, postage prepaid, on the Defendant, on the / z//.~_ day of January, 2002, as follows: Keith L. Plasterer Jamie L. Plasterer 36 Kelly Drive Carlisle, PA 17013 By: Benjamin ¢. Riggs~l'.r{J Attorney for Plaintiff 235 North Second Street P.O. Box 1711 Harrisburg, PA 17105-1711 Phone: (717) 815-4518 I.D. No. 72030 SHERIFF'S RETURN - CASE NO: 2002-00244 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WAYPOINT BANK VS PLASTERER KEITH L ET AL REGULAR DOUGLAS DONSEN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PLASTERER KEITH L the DEFENDANT , at 1515:00 HOURS, on the 29th day of January , 2002 at 36 KELLY DR CARLISLE, PA 17013 KEITH L. PLASTERER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 32.14 Sworn and Subscribed to before me this ~/ &~ day of ! ~rothonotary So Answers: R. Thomas Kline 01/30/2002 WAYPOINT BANK Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-00244 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WAYPOINT BANK VS PLASTERER KEITH L ET AL DOUGLAS DONSEN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PLASTERER JAMIE L the DEFENDANT , at 1515:00 HOURS, on the 29th day of January , 2002 at 36 KELLY DR CARLISLE, PA 17013 by handing to KEITH L. PLASTERER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~ day of  ~o~ A.D. ! 4Prothonotary So Answers: R. Thomas Kline 01/30/2002 WAYPOINT BANK Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WAYPOINT BANK F/K/A : YORK FEDERAL SAVINGS : AND LOAN ASSOCIATION AND : HARRIS SAVINGS BANK : Plaintiff : VS. KEITH L. PLASTERER JAMIE L. PLASTERER De~ndan~ No. 02-244 Civil Term GARNISHMENT INTERROGATORIES IN ATTACHMENT TO: Orrstown Bank 3580 Orrstown Road Orrstown, PA 17244 You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. DEFINITIONS AND INSTRUCTIONS Unless negated by the context of the Interrogatory, the following definitions are to be considered to be applicable to all Interrogatories contained herein: (A) recorded or graphic matter, however produced or reproduced. The term document(s) includes without limitation, correspondence, memoranda, interoffice communications, minutes, reports, notes, schedule, analysis, books of account, ledgers, invoices, pleadings, questionnaires, contracts, bills, checks, diaries, logs, recordings, telegrams, letters, and all other such documents, tangible or retrievable of any kind. Documents also include any preliminary notes and drafts of all the foregoing, in whatever form, for example: printed, typed, longhand, shorthand, on paper, paper tape, tabulating cards, ribbon blueprints, magnetic tape, microfilm, PHOTOGRAPHIC RECORDS, OR OTHER FORM. (B) With respect to documents, the term "identify" means to give the date, title, author and addressee; identify with respect to documents further means: "Document(s)" is an all inclusive term referring to any wdting and/or (ii) (iii) To describe a document sufficiently well enough to enable the interrogator to know what such document is and to retrieve it from a file or wherever it may be located; To describe it in a manner suitable for use as a description in a subpoena; To give the name, address, position or title of the person(s) who has custody of the document and/or copies thereof. (i) (C) "Identify "when used in reference to an individual means: (i) To state his/her full name; (ii) Present residence address or last-known address; (iii) Present or last known business address; (iv) Present employer or last-known employer; (v) Whether ever employed by any party to this action and, if so, the dates he (she) was employed by such party, the name of such party and the last position held as an employee of such party. (D) "Describe" when used in connection with, or with respect to, an agreement or event, means to state the place and time thereof, to identify all documents relating or referring thereto, to identify all persons present or having knowledge thereof, to state the subject matter and substance of the agreement or event, and to state the acts by each person who participated in any way. (E) "Person" when used as a term herein shall mean any natural person, firm, association, partnership, corporation or other form of legal entity or governmental body, unless the context of the question indicates otherwise. (F) "You" and "Your" apply and refer to the responding party or the person or persons who is/are responding on behalf of the responding party, and encompasses each and every person employed or working under the supervision, direction, or control of the responding party, to attorneys and agents, and to all other persons acting or proporting to act with actual or apparent authority on behalf of the party to whom these Interrogatories are addressed. (G) Defendant applies and refers to Keith L. Plasterer and Jamie L. Plasterer. (H) "Occurrence" shall mean the precipitating event, incident, act or manner of defendants actions, defendants conduct and/or the series or combined events, incidents, acts and conduct which gave rise to the claims for which he plaintiff seeks damages. (I) Whenever the expression "and/or" is used in these Interrogatories, the information called for should be set out both in the conjunctive and disjunctive, and whenever the information is set out in the disjunctive, it should be given separately for each and every element sought. (J) Whenever a date, amount or other computation or figure is requested, the exact date, amount or other computation is to be given unless it is not known; and then the approximate date, amount or other computation or figure should be given or the best estimate thereof; and the answer shall state the date, amount or other computation or figure is an estimate or approximation. (K) An Interrogatory asking you, to "state each fact which is the basis for" seeks disclosure of each and every fact, circumstances, condition, thing, or event known to you as of the date these Interrogatories are answered; full identification and description of the source(s) of such facts, circumstances, conditions, things, or events including, but not limited to identification and description of each document relating to or referring to each such fact, circumstance, condition, thing or event, unless otherwise protected by legal privilege; and requires that you identify each person involved and identify and described each document relating to any independent check made by your of which you have knowledge. (L) Each Interrogatory is intended to and does request that the particulars and parts thereof, are to be answered with the same force and effect as if each part was a subject of and asked by a separate Interrogatory. (M) No answer is to be left blank. If the answer to an Interrogatory or subparagraph of an Interrogatory is "none" or "unknown", such statement must be written in the answer. If the action is inapplicable, "IN/A" must be writ[en in the answer. If an answer is omitted because of the claim of privilege, the basis of the privilege is to be stated. (N) These Interrogatories are continuing, and any information secured subsequent to the filing of your answers which would have been includable in the answers had it been known or available, are to be supplied by supplemental answers. INTERROGATORIES 1. At the time you were served with these Intermgatoies in the above- captioned matter or at any subsequent time did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax, or other accounts or deposits in which the Defendant has an interest? If so, please state: (a) All account numbers, and titles and the balance of each (b) account; Whether the account is held individually, or jointly with any other party or parties and is so identify such other party. 2. At the time you were served with the Interrogatories in the above- captioned matter Or at any subsequent time did you owe the Defendant any money or were you liable to the Defendant on any negotiable or other written instrument or did Defendant claim that you owed them any money, or were liable to them for any reason? If so, please state: (a) Whether monies were due Defendant or if you were liable to Defendant as a result of a negotiable or other written document or claim; (b) the date of any negotiable or other written instrument or claim; The amount of any negotiable or written instrument or claim; (d) The reason for any negotiable or other written instrument or claim. 3. At the time you were served with the Interrogatories in the above- captioned matter, or at any subsequent time, was there in your possession, custody, or control of you and one or more other person any property of any nature owned solely or in par/by the Defendant. If so, state: (a) The names and addresses of any other parties who are or have been jointly in control with you of any property owned solely or in par/by Defendant; ~on e. (b) A description of any property in the control or custody of you and/or one or more Defendants? (c) The fair market value of the property. 4. At the time you were served with the Interrogatories in Execution in the above-captioned matter, or at any time, subsequent time, did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? If so, please state: (a) The description of any property owned solely by the Defendant to which you hold legal title; (b) The names and addresses of any individuals who jointly held or claimed any interest in any property with Defendant to which you hold legal title: (c) The description of any property in which Defendant held or claimed any interest in which you hold legal title; (d) The names and addresses of any individuals who jointly held or claimed any interest in any property with Defendant to which you hold legal title; (e) The value of any property owned solely or in part by Defendant or in which Defendant held or claimed any interest. 5. At the time you were served with the interrogatories in the above- captioned matter or at any subsequent time, did you hold as fiduciary any property in which the Defendant had any interest? If so, please state: (a) A description of any property you hold as fiduciary in which Defendant had any interest/ (bi The value of any property you hold as fiduciary in which Defendant had any interest; [one_. (c) The date of your dissolution as fiduciary. go , t 6. At any time before or after you were served which the Interrogatories in the above-captioned matter, did the Defendant transfer or deliver any property to you or to any pemon or place pursuant to your direction or consent, and what was the consideration therefor? If so, please state: (a) Specifically describe the property delivered or transferred; (bi State the fair market value of such property. ~ o i'~ .~ 7. At any time after you were served with the Writ of Execution in the above-captioned matter, did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to their direction otherwise discharge any claim of the Defendant against you? If so, please state: (a) A description of the property transferred or delivered to the Defendant; (b) The value of any property transferred or delivered to Defendant: (c) The amount of money delivered to the Defendant: (d) A description of any property transferred or delivered to any person or place pursuant to Defendant's direction; ~0~ ~_ (e) The names and addressed of any persons or places to which any property was transferred or delivered at Defendant's direction; (f) The value of any property transferred or delivered to any person or places pursuant to Defendant's direction; (g) The nature of any claim by Defendant against you and discharged by Defendant. Respectfully submitted, Waypoint Bank Date: By: Benjantin F. Rigg~l,~ r.~,/ Attorney for Plaintiff Waypoint Bank P. O. Box 1711 Harrisburg, PA 17105 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO02-244 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due WAY'POINT BANK F/ledA YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK l:~li~S"ff~-~'~l~ifl[~MIR L PLA'$i'ER~R 36 KELLEY DRIVE, CARLISLE PA (1) You are directed to levy upon thc property of the defendant(s) and to sell ALL PERSONAL "-O~P_~I~TV T tnt~ A WED AT 36 KELLY DI~VE CARLISI ~ ~ A (2) You are also directed to attach the property of the defend~t(~ le~i~'6on in the possession l~011~li]lg~Wl~ B~ 0t~80 ORRSTOWN ROAD, ORI~'rowN l'l~lnNA AInD ALLFIRST ~,~,~'i~ ** Lo £ HIGH STREET, CARLISLE PA L-waitp.Lxl~o~.,~ t ~ ~ aa follow.q: ~~ccov~rs ,~ ~{{~giiutify the garnishee(s) that: (a) an aFtachment has been issued; Co) mu garmsnce~s) Is/are enjoined ~h~.paying any debt to or for the account of the defendant (s) and from delivering any property of the~ erty of the defend~t(s) not levied upon an subject to attachment is found in the possession .--~__.~_~¢.r t~ a nord g~,-.isliee, ~ou are d~ected to notir~ ~i-~fher ~t he/she has be~ addcd~s a ~m~l~h~¢njoined as above stated. Garnishee ' ' Amount Due $ 55,059.62 Interest THROUGH JANUARY 11,2002 Atty'~ Corem-% ~.~Paid$~0.6~0 4 aha ~uoscribed to before me Plaintiff Paid L.L.$0.50 Due Prothy $1.00 Other Costs _ p.at_e:.AP~RIL 8, 2002 REQUESTING PARTY: Name: BENJAMIN F RIGGS, JR Address: P. O. BOX 1711 HARRISBURG, PA. 17105-17111 rrothono~y, ci_~l Attorney for: PLAINTIFF Telephone: 7178154518 Supreme Court ID No. 72030 R..Thomas Kline, Sheriff, who being duly sWorn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing $ 18.00 Poundage 2.55 Advertising Law Library .50 Prothonotary 1.00 Mileage Misc. Surcharge 50.00 Levy 40.00 Post Pone Sale Garnishee 18.00 130.05 Advance Costs: Sheriffs Costs: 150.00 130.05 ¢$.95 Refunded to Arty on4/30/02 Sworn and Subscribed to before me This 2~,kday of -)q~Ca~ 2002^.D. F2 l~o~onot~ So Ansyg. ers.;~ .. R. Thor~as Kline, Sheriff- R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee TOTAL $ 18.00 909.99 30.00 1.00 18.63 30.00 20.00 45.00 1072.62 Sworn and Subscribed to before me This /9' t: day of !Jl.u;> < (-I 7 2005 A.D. (1:;;/;4.' Cl hJ;V'J-t/ ,0f'i P thonotary , ~:;.;-.)) =CJ r:-~; 13 (_-_-~,:::J ,:;,7) :."iiil Advance Costs: Sheriff's Costs: 1 072.62 1 072.62 $0000.00 Refunded to Attyon 02/10/05 ~4t!.e rtff~n~ lJ ~Iaudia A. Brewbaker " " ~ . ' '- f I o,,~ ,Jil'J , " "J." J.;,U: ],,, .:UJ j, crJ -J g ~""1l =vlJ = ~ [fUil G/~ /.ff, Ru. /1 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N002-244 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WAYPOINT BANK FIKlA YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff (s) From KEITH L PLASTERER JAMIE L PLASTERER 36 KELLY DRIVE, CARLISLE P A (I) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF KEITH L PLASTERER AND JAMIE L PLASTERER LOCATED AT 36 KELLY DRIVE, CARLISLE, CUMBERLAND COUNTY PA (2) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (aJ an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as a garnishee and is eIjjoined as above stated. Amount Due$55,059.62 Interest THROUGH JANUARY 11, 2002 L.L. Atty's Comm % Atty Paid $223.69 Plaintiff Paid Date: AUGUST 6, 2002 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothonotary By: C).'f"- 0 h.. pD.. , Deputy REQUESTING PARTY: Name BENJAMIN F RIGGS JR Address: POBOX 1711 HARRISBURG PA 17105-1711 Attorney for: PLAINTIFF Telepbone: 717)815-4518 Supreme Court ill No. 72030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION I WAYPOINT BANK F/KlA YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff No. Oa. 01 '-'IV' {)!\hl jJ;eff\. vs. KEITH L. PLASTERER JAMIE L. PLASTERER Defendants Confession of Judgment PRAECIPE TO DISMISS AND SATISFY Please dismiss and satisfy the judgment that was filed on January 17, 2002 in the amount of $55,059.02 in relation to the above-referenced matter. Benjam~&!r,+ Attorney for Plaintiff P.O. Box 1711 Harrisburg, PA 17105-1711 (717) 815-4518 1.0. No. 72030 F.... '""