HomeMy WebLinkAbout04-4444HEMPT BROS., 1NC., )
Plaintiff )
)
)
ANDREW E. SNELL, )
Defendant )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2004- qqqy
CIVIL ACTION - LAW
CIVIL TERM
PRAECIPE
TO THE PROTHONOTARY:
Please enter judgment in favor of Plaintiff and against the Defendant in the original
judgment promissory note amount of $16,942.82, plus 20% attorney's commission of $3,388.56
for a total of $20,331.38, in accordance with the attached Judgment Promissory Note.
Respectfully submitted,
Attorney for Plaintiff
429 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
Supreme Court ID #41263
Date: August 31,2004
JUDGMENT PROMISSORY NOTE
AMOUNT: $16,942.82 DATE: '~C_~, LI ~r~ &C)O ~
ANDREW E. SNELL, the undersigned, promises to pay to the order of HEMPT BROS.,
1NC., the sum of SIXTEEN THOUSAND NINE HUNDRED FORTY-TWO AND 82/100
($16,942.82) DOLLARS, without offset, for value received, both prior to the entry of judgment
on this instrument and following entry ofjudgrne,t on this instrument and continuing until such
time as all sums due hereunder have been paid in full.
AND FURTHER, the undersigned does hereby authorize and empower any attorney of
any court of record of Permsylvania or elsewhere to appear for the undersigned and to enter
judgment against the undersigned in favor of any holder of this note for the above sum, together
with interest then due, and together with costs of suit, release of errors, and together with an
attorney's commission of twenty (20%) percent, and without stay of execution of any kind; and
the undersigned hereby waives and releases any and all benefit and relief from any and all
appraisement, stay or exemption laws of any state now in force or hereinafter to be passed.
ADDRESS:
ANDREW E. SNELL
DISCLOSURE STATEMENT
The undersigned, ANDREW E. SNELL, having read this document in its entirety, and
fully understanding it, hereby states, admits, acknowledges, and certifies the following:
1. I have, this day, signed a Judgment Promissory Note in which I promise to pay to
HEMPT BROS., INC., the stun of Sixteen Thousand Nine Hundred Forty-two and 82/100
($16,942.82) DOLLARS.
2, The said judgment note gives the persons who hold or own the note the fight to file
and enter judgment against me without any prior notice to me and without any right of formal
pleading, notice, or hearing for me before the entry of said judgment.
3. Such a judgment entered against me will automatically create a lien on all real estate
owned by me at that time, whether I own it now or acquire it later.
4. Such a judgment entered against me will entitle the person who owns or holds such a
judgment to issue execution against my property which can result in the Sheriffphysically
attaching or taking possession of said property and selling it at a Sheriffs Sale.
5. That I will be compelled and required to hire an attorney to file formal documents to
open or strike such a judgment ifI have a valid defense to the action taken against me, and
without those documents being filed, I will not have a right to a hearing or trial on such judgment
matter.
6. That 1 have an income, either myself or together with any other persons who signed
the note with me, which is at least $10,000.00 per year.
ADDRESS:
ANDREW E. SNELL
HEMPT BROS., INC., )
Plaintiff )
)
vs. )
)
ANDREW SNELL, t/a ANDREW SNELL )
CONCRETE and ANDREW E. SNELL and )
DENISE K. SNELL, his wife, Individually, )
Defendants )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO45q- ~,q~ CIVIL TERM
CIVIL ACTION - LAW
CERTIFICATE OF RESIDENCE
I hereby certify that the residences of the Plaimiff and Defendant Andrew E. Snell are as
follows:
Hempt Bros., Inc.
205 Creek Road
Camp Hill, PA 17011
Andrew E. Snell
30 Umberto Street
New Cumberland, PA 17070
Attorney for Plaintiff
429 South 18th Street
Camp Hill, PA 17011
HEMPT BROS., INC., )
Plaintiff )
)
)
ANDREW SNELL, t/a ANDREW SNELL )
CONCRETE and ANDREW E. SNELL and )
DENISE K. SNELL, his wife, Individually, )
Defendants )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. Oq-qt./qq CIVIL TERM
CIVIL ACTION - LAW
AFFIDAVIT
The Judgment by Confession is upon a Judgment Promissory Note in favor of the
Plaintiff and against Defendant Andrew E. Snell and is not be entered by confession against a
natural person in connection with a consumer credit transaction.
Counsel for Plaintiff
SWORN
BEFOR~IV
)AND SUBSCRIBED
~ ,2004.