Loading...
HomeMy WebLinkAbout12-0143SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 17 i,' J . 25 AFB : "EPOS L\lAN1A Orrstown Bank Case Number vs. Susan B. Deremer 2012-143 SHERIFF'S RETURN OF SERVICE 01/17/2012 06:28 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 17, 2012 at 1828 hours, he served a true copy of the within Complaint in Confession of Judgment, upon the within named defendant, to wit: Susan B.Deremer, by making known unto Robert Slagle, Husband of Defendant at 8 Foxfield Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. RYAN BURGETT, DE UT SHERIFF COST: $38.44 January 20, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ORRSTOWN BANK, PLAINTIFF V. SUSAN B. DEREMER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-143 CIVIL ORDER OF COURT AND NOW, this 15th day of February, 2012, upon consideration of the Defendant's Petition to Strike Off or Open Judgment, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Plaintiff to show cause why the relief requested should not be granted; 2. The Plaintiff will file an answer on or before March 9, 2012; 3. The Prothonotary is directed to forward said Answer to this Court. 4. Hearing/Argument on the matter will be held on Wednesday, March 21, 2012, at 3:00 p.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, ? Elizabeth Goldstein, Esquire Attorney for Plaintiff V Keith Brenneman, Esquire Attorney for Defendant bas CeP;e.S ma(moo( ??/.5??/? c a n4 _ M. L. Ebert, Jr., J. ? o? - Z 20 3 x r ? Ty r .11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ORRSTOWN BANK NO. 2012-143 vs. SUSAN B. DeREMER CIVIL ACTION - LAW ANSWER AND NEW MATTER OF PLAINTIFF, ORRSTOWN BANK TO PETITION OF SUSAN B. DEREMER TO STRIKE OFF OR OPEN JUDGMENT C-) c - co MM cn r? ? ca ? G N O co W Plaintiff, Orrstown Bank (the "Plaintiff or the Bank") hereby responds to Defendant, Susan B. DeRemer's ("DeRemer" or "Defendant") Petition to Strike Off or open Judgment (the "Petition") as follows: 1. Admitted. 2. Denied. The Complaint in Confession of Judgment (the "Complaint") is a written document which speaks for itself and the Defendant's incomplete and inaccurate paraphrase of that document is denied. 3. Denied. The Complaint is a written document which speaks for itself and the Defendant's incomplete and inaccurate paraphrase of that document is denied. 4. Denied. The Complaint is a written document which speaks for itself and the Defendant's incomplete and inaccurate paraphrase of that document is denied. 5. Denied as stated. On January 13, 2012, Orrstown Bank caused a judgment to be confessed against Defendant in the amount of $2,190,176.76 and a true and correct copy of the Entry of Appearance Confession of Judgment is attached to the Petition as Exhibit A. Pleading further, the Entry of Appearance Confession of Judgment is a written document which speaks for itself and the Defendant's incomplete and inaccurate rri --- r- t? ; 8765646_4 .J1 paraphrase of that document is denied. Pleading further, any discrepancy among that and other documents is immaterial and nonprejudicial and was otherwise waived. 6. Denied. The Complaint and the Judgment are written documents which speak for themselves and Defendant's incomplete and inaccurate paraphrase of those documents is denied. Pleading further, the amount of the judgment, $2,190,176.76, is the same amount set forth in the Entry of Appearance Confession of Judgment and also the same amount which is set forth in the prayer for relief in the Complaint. 7. Denied. Paragraph 7 contains a conclusion of law which no responsive pleading is required. To the extent a responsive pleading is required, on January 13, 2012, Marvin Window and Door Showplace, Inc. ("Marvin Window") was in default of payment obligations to Plaintiff under the note. Pleading further, demand had been made under the note and guaranty and all amounts were due thereunder on or before January 13, 2012. Those amounts were not paid on or before that date. 8. Denied. Paragraph 8 contains a conclusion of law which no responsive pleading is required. To the extent; a responsive pleading is required, on January 13, 2012, Defendant was in default of her guarantee. Pleading further, demand had been made under the note and guarantees and all amounts were due thereunder on or before January 13, 2012. Those amounts were not paid on or before that date. 9. Denied. Notices were sent to Marvin Window (to the attention of its President, Susan DeRemer Slagle) and the guarantors of the Note, namely Robert Slagle, Susan DeRemer Slagle and Lightstyles, Ltd. (to the attention of its President, Robert Slagle). Certain of the notices were not accepted by the individuals. True and correct copies of the notices are attached hereto as Exhibits 1 through 4. 87656464 2 ?r 10. Denied. Paragraph 10 contains a conclusion of law to which no responsive pleading is required. To the extent a responsive pleading is required, upon information and belief, Defendant is aware of circumstances which would place the note and guarantees in default including, but not limited to: (a) failure to pay all amounts due when demanded; (b) The bank being afforded reasonable grounds for insecurity for the repayment of its indebtedness based on, among other things, the financial circumstances of the Defendant; and (c) failure to cooperate with the bank's request for information regarding the borrower. 11. Denied. Paragraph 11 contains a conclusion of law to which no responsive pleading is required. To the extent a responsive pleading is required, the Plaintiff has complied with Pa. R.C.P. 2962 in that, among other things, the confession package does substantially comply with the requirements of Rules 2955 and 2962. See also Stein v. Penncrest Construction Corp., 280 Pa. Super. 560, 421 A.2d 1074 (1980) (affirming denial of petition to strike judgment finding that, despite failure by judgment creditor's attorney to explicitly enter his appearance for defendant, documents construed as a whole made it apparent that appearance and judgment were being entered against defendant in favor of judgment creditor). 12. Denied. Paragraph 12 contains a conclusion of law to which no responsive pleading is required. To the extent a responsive pleading is required, the Plaintiff has complied with Pa. R.C.P. 2962 in that, among other things, the confession package does substantially comply with the requirements of Rules 2955 and 2962. See also Stein v. Penncrest Construction Corp., 280 Pa. Super. 560, 421 A.2d 1074 (1980). 87656464 3 13. Denied. Paragraph 13 contains a conclusion of law to which no responsive pleading is required. 14. Denied. Paragraph 14 contains a conclusion of law to which no responsive pleading is required. 15. Denied. Paragraph 15 contains a conclusion of law to which no responsive pleading is required. 16. Denied. The Entry of Appearance Confession of Judgment is a written document which speaks for itself and Defendant's incomplete and inaccurate paraphrase of that document is denied. Pleading further, Plaintiff incorporates its response to paragraph 10 hereof. 17. Denied. The Entry of Appearance Confession of Judgment is a written document which speaks for itself and Defendant's incomplete and inaccurate paraphrase of that document is denied. Pleading further, Plaintiff incorporates its response to paragraph 10 hereof. 18. Denied. Paragraph 18 contains a conclusion of law to which no responsive pleading is required. To the extent that a responsive pleading is required, the Note is a written document which speaks for itself and Plaintiff's incomplete and inaccurate paraphrase of that document is denied. 19. Denied. Paragraph 19 contains a conclusion of law to which no responsive pleading is required. Pleading further, the note at issue in this case is a demand note and demand was made under the note. Moreover, Defendant was in default of the note as set forth in paragraphs 8 and 9 above. Plaintiff properly demanded amounts due under the note. 4 87656464 WHEREFORE, the Plaintiff requests that Defendant's Petition to Strike Off or Open Judgment be denied. NEW MATTER 20. Plaintiff incorporates the averments set forth in paragraphs 1 through 19 above as if set forth at length herein. 21. Plaintiff's judgment should not be stricken because there is no defect on the face of Plaintiff's Complaint in Confession of Judgment that would require Plaintiff s judgment to be stricken. 22. Plaintiff s judgment should not be opened because Defendant has failed to plead a meritorious defense to Plaintiff s Complaint and Confession of Judgment. WHEREFORE, Plaintiff requests that Defendant's Petition to Strike Off or Open Judgment be dismissed. Respectfully submitted, Marti Weis (I.D. No. 51379) Elizabeth Goldstein (I.D. No. 73779) Dilworth Paxson LLP 112 Market St., Suite 800 Harrisburg, PA 17101 (717) 236-4812 Attorneys for Orrstown Bank 5 87656464 Exhibit "1 A" . . : 1i Dilworth Paxson, f ? tfw-111 '1 Mardn 1. Weis mweis@dilworthlaw.com November 2, 2011 VIA UPS OVERNIGHT MAIL Marvin Window and Door Showplace, Inc. Attention: Susan DeRemer Slagle, President 1216 Claremont Road Carlisle, PA 17015 RE: Promissory Note dated June 1, 2010 (Loan No. 13323003011 Dear Ms. Slagle: This office represents Orrstown Bank in connection with the above-referenced matter. On June 1, 2010, Marvin Window and Door Showplace, Inc. (the "Borrower") executed in favor of Orrstown Bank (the "Bank") a promissory note in the original amount of $2,100,000.00 bearing interest at an initial interest rate of 5% (the "Note"). The Note is secured by, among other things, mortgages and assignments of rents on real property located at 1267 Allendale Road, Mechanicsburg, PA 17055; 39691 Hampton Lane, North Bethany, DE 19930; and 8 Foxfield Court, Mechanicsburg, PA 17050; life insurance policies described in a certain assignment of life insurance polices dated June 1, 2010; and inventory chattel, paper, accounts, equipment, general intangibles and other assets of the Borrower. The Note is guaranteed by Robert L. Slagle, Susan E. DeRemer Slagle, and Lightstyles, Ltd. The amounts owed as of October 31, 2011 are as follows: Principal: $2,076,817.15 Interest: $ 8,652.30 Loan Admin Fee $ 300.00 Total $2,085,769.45 The per diem interest on the Note is $288.24. Pursuant to the terms of the Note, Orrstown Bank hereby demands that payment in full of the Note be made on or before December 2, 2011. Payment should be sent to: U2 Market Street • Suite 800 • Harrisburg, PA 17101-2015 . 717-236-4812 . fax: 717-236-78U sm"dUrorthlawcom . Philadelphia, PA . Cherry Hill, NJ . Washington, DC . Neptune, NJ . Wihnington, DE Marvin Window and Door Showplace, Inc. November 2, 2011 Page 2 Orrstown Bank 2695 Philadelphia Avenue Chambersburg, PA 17201 Attention: Bradley Tanguay If you would prefer to pay this by wire, please contact Mr. Tanguay at Orrstown Bank to arrange for wire instructions. Partial payments will be accepted and credited against your accounts however, they will not relieve the Borrower of its obligations under the Note and this letter. Failure to pay in accordance with this letter shall cause a default under the Note and may cause the Bank to, without further notice to the Borrower or guarantors, take all appropriate action and institute all appropriate legal proceedings which the Bank deems necessary to assure full collection of the amount due on the Note. These proceedings could include, but are not limited to, filing a civil action or confession of judgment proceeding against the Borrower or any of the guarantors. You will be responsible for legal fees incurred by the Bank in connection with the collection of such outstanding amounts. By delivering this letter, the Bank is not waiving any rights, powers or privileges granted to the Bank by the Note or the various other documents and instruments executed by the Borrower and others as collateral for the Note. The Bank hereby expressly reserves all of its rights with respect to enforcing any and all such rights, powers or privileges at any time in the future. In no event shall the Bank's delay in exercising, or its failure to exercise, any and all of the Bank's rights, powers, privileges or remedies, nor the Bank's partial exercise of the same, constitute a waiver or release of any of the Bank's rights, powers, privileges or remedies. Sincerely, ?avfn J-." 4? Martin J. Weis MJW:fcw cc: Robert Slagle Susan B. DeRemer Lightstyles, Ltd. 82814334 Exhibit "1B' UPS CampusShip: Shipment R °ipt Shipment Receipt Transaction Date: 02 Nov 2011 Trackin Number: 1Z66VO43A290768758 1M Address information Ship To: Ship Prom: Marvin Window & Door Showplace Inc. Dilworth Paxson - Harrisburg Attn: Susan DeRemer Slagle, Pres. ELLEN YASINSKI 1216 Claremont Road 112 Market Street, 8th Floor CARLISLE PA 170159742 Harrisburg PA 17101 Telephone:8008470655 Return Address: Dilworth Paxson - Harrisburg ELLEN YASINSKI 112 Market Street, 8th Floor Harrisburg PA 17101 l"ele hone:8008470655 [2 Package information Weight Dimensions / Declared Value Reference Numbers Packaging 1. Letter UPS Letter Client/Matter - 295121949% Attorney Name - Martin J. Weis, Esq. UPS Shipping Service and Shipping Options Service: UPS Next Day Air Guaranteed By: 10:30 AM Thursday, 11/3/11 Additional Shipping Options Delivery Confirmation: Package 1: Adult Signature Required Total Shipping Charges ® Payment information Bill Shipping Charges to: Shipper's Account 66VO43 You are not authorized to view rates information. All Shipping Charges in USD Page I of I Note: Your invoice may vary from the displayed reference rates. • For delivery and guarantee information, see the UPS Service Guide. To speak to a customer service representative, call 1.800-PICK-UI domestic services and 1-800-782-7892 for International services. https://www.campusship.ups.com/cship/create?ActionOriginPair-default PrintWindow... 11/2/2011 UPS: Tracking Information http://wwwapps.ups.com VebT... Monday, November 07, 2011 United States New User I Log-in My UPS Shipping Tracking Freight Locations Support UPS Tracking Number Track Loa-in for additional tracking details. Tracking Detail 1Z66V043A290768768 I Delivered Delivered On: Thursday, 11/03/2011 at 9:27 A.M. Left At: Receiver Special Instructions: Adult Signature Required Signed By: SCOTT Proof of Delivery I Request Status Updates Additional Information Shipped/Billed On: 11/02/2011 i Type: Package Shipment Progress What's T Subscribe to UPS E-mail: JTntere-malt address Sign Up n view Examples contact UPS Support Solutions for. 1Browse Online Support Get Started Healthcare WIF.dwil UPS W der Small Business Call Customer Service Open a Shipping Account a High Tech Chan-W Your Delivery More... ATTN : ALLEN TOMPKINS PHONE : (215)575-7117 DELIVERY NOTIFICAMN INQUIRY FROM: .Jovember 7, 2011 Shipper 66VO43 Page 1 of 1 DILWORTH PAXSON LLP 112 MARKET ST FLR 8 HARRISBURG PA 17101 ATTN: SUSAN DEREMER SLAGLE, MARVIN WINDOW & DOOR SHOWPLA 1261 CLAREMONT RD CARLISLE PA 17015 Shipper Number ............................66VO43 . Tracking Identification Number... 1Z66V043A290768758 According to our records 1 parcel was delivered on 11/03/11 at 9:27 A.M.. The shipment was signed for by SCOTT as follows: SHIPPER PKG TRACKING ADDRESS NUMBER to NO. NUMBER (No/BTRmcny) SIGNATURE 66VO43 1Z85V013A211 M755 17181 CLAREMONT RD CARLISLE TPA2176:OOOA0000 Exhibit "1 C" UPS CampusShip: Shipment Receipt Shipment Receipt Transaction Date: 02 Nov 2011 Trackin Number. 1Z;66V043AZ9U40tMW 13 Address Information Ship To: Ship From: Robert L. Slagle Dilworth Paxson - Harrisburg 8 Foxfieki Court ELLEN YASINSKI MECHANICSBURG PA 170507339 112 Market Street, 8th Floor Harrisburg PA 17101 Residential Telephone:8008470655 Retum Address: Dilworth Paxson - Harrisburg ELLEN YASINSKI 112 Market Street, 8th Floor Harrisburg PA 17101 U2 Package information Weight Dimensions / Packaging Declared Value Reference Numbers 1. Letter UPS Letter Client/Matter - 29512194996 Attorney Name - Martin J. Weis, Esq. Q UPS Shipping Service and Shipping Options Service: UPS Next Day Air Guaranteed By: 10:30 AM Thursday, 1113/11 Additional Shipping Options Delivery Confirmation: Package 1: Adult Signature Required Total Shipping Charges M Payment information Bill Shipping Charges to, Ship is Account 66VO43 F You are not authorized to view rates information. All Shipping Charges in USD Page 1 of 1 Note: Your invoice may vary from the displayed reference rates. For delivery and guarantee information, see the UPS Service Guide. To speak to a customer service representative, call 1-900-PICK-Ul domestic services and 1-800-782-7892 for international services. https://www.campusship.ups.com/cship/create?ActionOriginPair-default?PrintWindow... 11/2/2011 UPS: Tracking Information http://vwvwapps.ups.com/WebT... Monday, November 07, 2011 United States New User i Logdn Contact UPS i The UPS Store SearNr„ _ i Sul. My UPS Shipping Tracking Freight Locations Support UPS Solutions I ranking Number Track Loo-In for additional tracking details. - - -- pear Tracdtl?O hp rids i,: ?? ¦.?a?re?¦e¦r?r.?urerraa?¦t_ Tracking Detail IZ66v043A290406669 PdM M2 A A A Updated: 11;0712011 11:16 A.M. Eastern Time Final Attempt Made Lam Location. ? Change Delivery b J f Harrisburg, PA, United States, Monday, 11!0712011 ?J Special Instnwdons. Request Status Updates n Adult Signature Reguired I i FLcation Date Tim t Activity Harrisburg, PA, United States 11/07/2011 921 A.M. The customer was not available on 3rd attempt. 11/0712011 5:20 A.M. Out For Delivery I I Harrisburg, PA, United States 11104/2011 9:18 A.M. The customer was not available on the 2nd attempt A 3rd i I attempt will be made. I i r ?i Harrisburg, PA, United States 11/0312011 9:18 P.M. Destination Scan i ' 1 11/03/2011 10:27 A.M. The customer was not available on the 1 st attempt. A 2nd attempt wdi be made. Harrisburg, PA, United States 11/0212011 9:38 P.M. Destination Scan 11/0212011 826 P.M. Origin Scan l 11/02f2011 4:06 P.M. Pickup Scan i { Untied States 11/02f2011 11:48 A.M. Order Processed: Ready for UPS r- Shipping Information To: MECHANICSBURG, PA, US Shipped By UPS Next Day AjYO Additional Infotnlation *!Fi UPSUrotacr I hipped/Bilied On: 11/02/2011 TIRED OF Ype: Package GETTING Shipment Progress JUhat's Tn s? ? THIS? Subscribe to UPS E-mail: ntrE ere-maY address Sign Up a View Euamces § ft Fygfloeuc Contact UPS Sum* Soludons for: Other UPS Sites: { Pflm a Oniina Support I Get Started Healthcare Select a webstte ?% 7'' ?rralt UPS I Small ausiness ---- f Call Customer Service 1 Open a SNWM A Y tliGh Tech I Cheops Your Delivarv More,.. W E9LOGISrIa' 2M About UPS Sne Quids tpy?gg Cptyuy UPS %bal UPS Noble UPS Bba Smloe Terms and CondiCons we6sue Taps d Use Pdvacv Poky p .y Aminat Fraud Copyrreh101994.2011 Unlled t>arcel liervics orAmerke, Ins M rtyhts reaervad. UPS: Tracking Information Page 1 of 1 United States Welcome, Lori A. Zimmerman (Not Me?) I Logout My UPS Shipping Tracking Freight Locations Support UP Tracking Number Track View Trackinu History View secure details (e.g., digital signature) for this vis' , or add this account Tracking Detail 1 Z66V043A290405569 Add Description Final Attempt Made Last Location: Harrisburg, PA, United States, Monday, 11/0712011 Special Instructions: Adult Slanature Required Change Delivery)) Request Status Updates » Report a Claim)) Additional Information Shipped/Billed On: 11102/2011 Type: Package Shipment Progress What's Location Date Local Activity Time Hamsourg, PA, united States 11107/2011 6:35 P.M. The customer was not available on 3rd attempt. / A postcard has been sent to the recipient requesting tt contact UPS. 11/07/2011 9:21 A.M. The customer was not available on 3rd attempt. 11/07/2011 5:20 A.M. Out For Delivery Harrisburg, PA, United States 11/04/2011 9:18 A.M. The customer was not available on the 2nd attempt. attempt will be made. Harrisburg, PA, United States 11103/2011 9:18 P.M. Destination Scan 11/03/2011 10:27 A.M. The customer was not available on the 1st attempt. , attempt will be made. http://wwwapps.ups.com/WebTracking/track 11/15/2011 Exhibit "I D" upN f?ampusbtnp: atupment Receipt Page 1 of 1 Shipment Receipt Transaction Date: 02 Nov 2011 TracKin Nlamper: 1Z55VO43AZU1754112 1® Address Information Ship To: Ship From: Susan B. DeRemer Dilworth Paxson - Harrisburg a/k/a Susan DeRemer Slagle ELLEN YASINSKI 8 Foxfieid Court 112 Market Street, 8th Floor MECHANICSBURG PA 970507339 Harrisburg PA 17101 Telephone:8008470655 Residential Return Address: Dilworth Paxson - Harrisburg ELLEN YASINSKI 112 Market Street, 8th Floor Harrisburg PA 17101 2M Package Information I Weight Dimensions / Declared Value Reference Numbers Packaging 1. Letter UPS Letter Client/Matter - 29512/94996 Attorney Name - Martin J. Weis, Esq. I M UPS Shipping Service and Shipping Options Service: UPS Next Day Air Guaranteed By: 10:30 AM Thursday, 1113/11 Additional Shipping Options Delivery Confirmation: Package 1: Adult Signature Required Total Shipping Charges M Payment Information 1 Bill Shipping Charges to: Shipper's Account 66VO43 I You are not authorized to view rates information. All Shippina Charsaes in USD Note: Your invoice may vary from the displayed reference rates. For delivery and guarantee Information, see the UPS Service Guide. To speak to a customer service representative, call 1-800-PICK-U1 domestic services and 1-800-782-7892 for international services. https://www.campussMp.ups.com/cship/create?ActionOriginPair-default PrintWindow... 11/2/2011 UPS:' Tracking Information http://wwwapps.ups.com/WebT... Monday, November 07, 2011 United States New User Login My UPS Shipping Tracking Freight Locations Support UPS., Tracking Number __ Track Log-In for additional tracking details. Tracking Detail"" 1Z66V043A291764172 s Final Attempt Made Last Location: I Change Delivery » Harrisburg, PA, United States, Monday, 11/07/2011 i Special Instructions: Request Status Updates » Adult Signature Required Additional Information Shipped/Billed On: 11/0212011 Type: Package Shipment Progress What's T Location Date Local Activity T? Time Harrisburg, PA, United States 11/07/2011 9:21 A.M. The customer was not available on 3rd attempt. 11/07/2011 5:20 A.M. Out For Delivery Harrisburg, PA, United States 11/04/2011 9:18 A.M. The customer was not available on the 2nd attempt. A attempt will be made. Harrisburg, PA, United States 11/03/2011 10:27 A.M. The customer was not available on the 1st attempt. A,e attempt will be made. Harrisburg, PA, United States 11102/2011 9:39 P.M. Destination Scan 11/02/2011 8:17 P.M. Origin Scan 11/02/2011 4:06 P.M. Pickup Scan United States 11/02/2011 11:50 A.M. Order Processed: Ready for UPS UPS: Tracking Information Page 1 of 2 United States Welcome, Lori A. Zimmerman (Not Mel) I Logout My UPS Shipping Tracking Freight Locations Support UP T racking Number Track View Trackina History View secure details (e.g., digital signature) for this visit, or add this account I Tracking Detail 1 Z66V043A291764172 Add Description Final Attempt Made L Last Location: Change Delivery » Harrisburg, PA, United States, Monday, 11/07/2011 Special instructions: Request Status Updates » Adult Slanature Required Report a Claim Additional Information Shipped/Billed On: 11/0212011 Type: Package Shipment Progress What, Location Date Local Activity Time Harrisburg, PA, United States 11/07/2011 6:35 P.M. The customer was not available on 3rd attempt. / A postcard has been sent to the recipient requesting tt contact UPS. 11/0712011 9:21 A.M. The customer was not available on 3rd attempt. 11107/2011 5:20 A.M. Out For Delivery Harrisburg, PA, United States 11/04/2011 9:16 A.M. The customer was not available on the 2nd attempt. attempt will be made. Harrisburg, PA, United States 11/03/2011 10:27 A.M. The customer was not available on the 1 st attempt. , attempt will be made. Harrisburg, PA, United States 11/02/2011 9:39 P.M. Destination Scan http://wwwapps. ups.con/WebTracking/track?loc=en_US 11/15/2011 UPS: Tracking Information United States 11/02/2011 8:17 P.M. Origin Scan 11/02/2011 4:06 P.M. Pickup Scan 11/02/2011 11:50 A.M. Order Processed: Ready for UPS Page 2 of 2 Subscribe to UPS E-mail: ;'Enter e-mail address Sign Up u View Examples Contact UPS sunoort Solutions for: ;flBrowse Online Support Q Lt Started Healthcare F , -mail UPS Register Small Business Call Customer gervice Open a Shinainc Account a High Tech Change Your Delivery More... Home About UPS Sfte Guide Investors Careers Pressroom UPS Global UPSN Service Terms and Conditions Website Terms of Use Privacy Policy ProtectAga Copyright ®1994-2011 United Parcel Service of America, Inc. All rights reservi http://wwwapps.ups.com/WebTracking/t-ack?loc=en_US 11/15/2011 Exhibit "1 E" urn;-ampusz)mp: stnpment xr 'pt Shipment Receipt Transaction Date: U0 Traekina Number. 02 Nov 2011 1Z66V043A290018586 Address Information Ship To: Ship From: Return Address: Lightstyles LTD Dilworth Paxson - Harrisburg Dilworth Paxson - Harrisburg Attn: Robert L. Slagle ELLEN YASINSKI ELLEN YASINSKI 1216 Claremont Road 112 Market Street, 8th Floor 112 Market Street, 8th Floor CARLISLE PA 170159742 Harrisburg PA 17101 Harrisburg PA 17101 Tele hone:8008470655 Tele hone:8008470655 Package information Weight Dimensions 1 Packaging Declared Value Reference Numbers 1. Letter UPS Letter Client/Matter - 29512/94996 Attomey Name - Martin J. Weis, Esq. UPS Shipping Service and Shipping Options Service: UPS Next Day Air Guaranteed By: 10:30 AM Thursday, 11/3111 Additional Shipping Options Delivery Confirmation: Package 1: Adult Signature Required Total Shipping Charges 1] Payment information BIN Shi i Cha es to: Shippers Account 66V043 I You are not authorized to view rates information. All Shipping Charges In USD Page Iof I Mote; Your invoice may vary from the displayed reference rates. " For delivery and guarantee information, see the UPS Service Guide. To speak to a customer service representative, call 14800-PICK-UI domestic services and 1-600-782-7892 for international senrioes. https://www.campusship.ups.com/eship/create?ActionOriginPair-default PrintWindow... 11/2/2011 ATTN : ALLEN TOMPKINS PHONE : (215)575-7117 DELIVERY NOTIFICATION INQUIRY FROM: DILWORTH PAXSON LLP 112 MARKET ST FLR 8 HARRISBURG PA 17101 November 7, 2011 Shipper 66VO43 Page 1 of 1 SHIPMENT TO: ATTN: ROBERT L. SLAGLE LIGHTSTYLES LTD 1261 CLAREMONT RD CARLISLE PA 17015 Shipper Number ............................ 6OV043 Tracking tdenU ication Number... 1Z66VO43A290018586 According to our records 1 parcel was delivered on 11/03/11 at 9:27 A.M.. The shipment was signed for by SCOTT as follows: SHIPPER PKG TRACKING ADDRESS NUMBER 10 NO. NUMBER (NO)STREET.CITY SIGNATURE 66VO43 1265V043A2WQ16566 1261 CLAREMONr RD CARLISLE TPA2176:000A0000 UPS: Tracking Information http://wwwapps.ups.com/WebT... Monday, November 07, 2011 United States New User i Log-In My UPS Shipping Tracking Freight Locations Support UPS iTracking Number _^! Track Loci-in for additional tracking details. Tracking Detail 1 Z66V043A290018586 Delivered I Delivered On: Thursday, 11/03/2011 at 9:27 A.M. Request Status Updates)) Left At. j Receiver Special instructions: f Adult Signature Required Signed By: i SCOTT Proof of Delivery Additional Information Shipped/Billed On: 11/02/2011 Type: Package i Shipment Progress What's•T Subscribe to UPS E-mail: iEntere-mail address Sign Up » View Examples Contact UPS I Su ort Solutions for: Browse Online Support Get Started Healthcare ME-mail UPS i ter Small Business k-Call Customer Service Open a Shipping Accour a High Tech Chance Your Delivery re... Exhibit "2A" Dilworth Paxson Martin J. Weis mweis@ditworffilaw.com December 6, 2011 VIA UPS OVERNIGHT MAIL Mr. Robert L. Slagle 8 Foxfield Court Mechanicsburg, PA 17050 RE: Promissory Note dated June 1, 2010 [Loan No. 1332300301 ] Dear Mr. Slagle: This office represents Orrstown Bank in connection with the above referenced matter. On June 1, 2010, Marvin Window and Door Showplace, Inc. (the "Borrower") executed in favor of Orrstown Bank (the "Bank") a promissory note in the original amount of $2,100,000.00 bearing interest at an initial interest rate of 5% (the "Note"). The Note is secured by, among other things, mortgages and assignments of rents on real property located at 1267 Allendale Road, Mechanicsburg, PA 17055; 39691 Hampton Lane, North Bethany, DE 19930; and 8 Foxfield Court, Mechanicsburg, PA 17050; life insurance policies described in a certain assignment of life insurance polices dated June 1, 2010; and inventory chattel, paper, accounts, equipment, general intangibles and other assets of the Borrower. The Note is guaranteed by Robert L. Slagle, Susan E. DeRemer Slagle, and Lightstyles, Ltd. The a mounts owed as of October 31, 2011 are as follows: Principal: $2,076,817.15 Interest: $ 8,941.85 Loan Admin Fee $ 300.00 Legal Fees $ 3,000.00 Total $2,089,058.90 The per diem interest on the Note is $288.24. 1500 Market Street • Suite 3500E • Philadelphia, PA 19102-7101. 215-575 7000 • fax: 215-575-7200 84ygq-jilworthlawcom • Cherry Hill, NJ • Harrisburg, PA • Washington, DC • Neptune, NJ • Wilmington, DE Mr. Robert L. Slagle December 6, 2011 Page 2 On November 2, 2011, the Bank demanded repayment of the Note on or before December 2, 2011. To date that payment has not been received and the loan is in default. Pursuant to the terms of your commercial guaranty dated June 1, Orrstown Bank hereby demands that payment in full of the Note be made on or before December 28, 2011. Payment should be sent to: Orrstown Bank 2695 Philadelphia Avenue Chambersburg, PA 17201 Attention: Bradley Tanguay Partial payments will be accepted and credited against your accounts however, they will not relieve the guarantor of its obligations under the guaranty and this letter. Failure to pay in accordance with this letter shall cause a default under the guaranty and may cause the Bank to, without further notice to the Borrower or guarantors, take all appropriate action and institute all appropriate legal proceedings which the Bank deems necessary to assure full collection of the amount due on the Note and guaranties. These proceedings could include, but are not limited to, filing a civil action or confession of judgment proceeding against the Borrower or any of the guarantors. You will be responsible for legal fees incurred by the Bank in connection with the collection of such outstanding amounts. By delivering this letter, the Bank is not waiving any rights, powers or privileges granted to the Bank by the Note or the various other documents and instruments executed by the Borrower and others as collateral for the Note. The Bank hereby expressly reserves all of its rights with respect to enforcing any and all such rights, powers or privileges at any time in the future. In no event shall the Bank's delay in exercising, or its failure to exercise, any and all of the Bank's rights, powers, privileges or remedies, nor the Bank's partial exercise of the same, constitute a waiver or release of any of the Bank's rights, powers, privileges or remedies. Sincerely, / I?v A Martin J. Weis MJW:lz 84319902 Exhibit "2B" • XV 80% Post-Consumer o^ ? S 4 9 •• o n. a 2' d ? sA g° s R n' 3 R. j O J ? o 3 N is se a a ?. $ 3 3 5 £ n 3 K d oQ° ? n A §a o ? D - n s ? n O c e' < o ? a H E c f a no ti r= N Cd a Vf H w •J A O O 11 C3. N b p- N N O •C? all Sri. Y LORI A. ZIMMERMAN 0 ?? LTA ? OF ? (215) 575.7097 7097 DILWORTH PAXSON - PHILADELPHIA 1500 MARKET STREET PHILADELPHIA PA 19102 SHIP TO: ROBERT L. SLAGLE ROBERT L. SLAGLE 8 FOXFIELD COURT MECHANICSBURG PA 17050-7339 ?- • , . PA 171 9-10 /\ N4,- UPS NEXT DAY AIR TRACKING #: 1Z V69 50R 24 9462 5551 BILLING: P/P SIGNATURE REQUIRED Gtt am2951?194996 Attomey orney Name: Martin J. Weis ca 136.i2 ar+trno 22.a 10/201 1 S ? i R s? { N OL C ro o p e{ x c n ? a .a t10 lJ 'C7 ?C R Sx.' {, v A V1 7.- 00 V V C. 7 1 V ?L ?• 4 Q• ? o n c 0 r•f t?A N V?1 Z 4 O t ? ? phi I r ?x3 N a yn r a AI nl H m C ID O b rD N O e ro ro 0 O` N ro fl ro v. UPS: Tracking Information http://NAwwapps.ups.com/WebT... Monday, March 05, 2012 United States New User I Loy-In I Contact UPS I The UPS Store Search Sul: My UPS Shipping Tracking Freight Locations Support UPS Solutions Tracking Number Track La•in for additional tracking details. Other Tracking Options ':R _._..---- -..._ .._..---- - --- ........ --- .,.._ -- ...... --- Tracking Detail Pdr, tt!2 [a iAj? lI 1ZV69SOR2494625561 Alternate Tracking Number : 1ZV6950R1294625556 Returning to Sender Last Location: Harrisburg, PA, United States, Friday, 12116/2011 I Special Instructions: Signature Required Additional Information ShippedlBilled On: Type: Updated: 03105,'2012 4:42 P M. Eastern Time Shipping Information To: PHILADELPHIA, PA, US Change Delivery » -? Shipped By Request Status Updates a UPS Next Day Air@ 12/06/2011 Package r0 urs My 0.111 TIRED Of GETTING ?._._. THIS? " ..rte Shipment Progress What's Th:s Location Date Local Activity Time Harrisburg, PA, United States 12116/2011 4:50 P.M. The customer was not available on 3rd attempt, / Returned to shipper. Alternate Tracking Number i 1ZV695OR1294625556 Harrisburg, PA, United States 12/09/2011 6:45 P.M. The customer was not available on 3rd attempt. / A Postcard has been sent to the recipient requesting that they contact UPS. i j 12/09/2011 9:11 A.M. The customer was not available on 3rd attempt 12109/2011 2:54 A, M. Out cor Delivery Harrisburg, PA, United States 12/06/2011 9:12 A.M. The customer was not available on the 2nd attempt. A 3rd attempt will be made. 12/08/2011 4:10 A.M. Out For Delivery Harrisburg, PA United States 12/0712011 923 A.M. The customer was not available on the 1st attempt. A 2nd attempt will be made. i 12/07/2011 7:06 A.M. Out For Delivery Middletown, PA, United States 12/07/2011 6:16 A.M. Departure Scan i 12/0712011 4:55 A.M. Arrival Scan Philadelphia, PA, United States 12/07/2011 2:57 A M. Departure Scan i 12107/2011 12:01 A.M. AmvV Scan Philadelphia, PA, United States 12106/2011 11:22 P M Departure Scan 1210612011 7:41 P.M Origin Scan 12106/2011 6:31 P.M. Pickup Scan ! United States 12)0612011 11:00 A.M. ¦?manm?m? s Order Processed Ready for UPS ta? t cs?mas oa r®aa4?saeerarm® Subscribe to UPS E-mail: En;et a-mail adciress Sign Up i> J; _.v E?anp;es $lie reedgp contact UPS Suooort Solutions for: Other UPS Sites: ,,Browse Online Suuoon a Started Healthcare Select a website - E {nail UPS Register Small Business UPS: Tracking Information http://wwwapps.ups.com/WebT... Monday, March 05, 2012 Live 'hat n7 i Open a Shipping Account III High Tech `Call Customer SeryiCR i Change Your 0eliverv More, WE C'IOGi$TIC$ Home About UPS Si a uid Investors Careers Pressroom UPS Global UP Mobil UPS Slog Service Terms and Conditions Websile Terms of Use PrivacyNolioe O Your California Privacy Rights D ProleU Aaainel Fraud Copyright 0 1991.2012 Uniled Parcel Service of America, Ina. Ali rights reserved. Exhibit "3A" Dilworth Paxson Martin J. Weis mweis@dilworthlaw.com December 6, 2011 VIA, UPS OVERNIGHT MAIL Ms. Susan B. DeRemer 8 Foxfield Court Mechanicsburg, PA 17050 RE: Promissory Note dated June 1, 2010 [Loan No. 1332300301] Dear Ms. DeRemer: This office represents Orrstown Bank in connection with the above referenced matter. On June 1, 2010, Marvin Window and Door Showplace, Inc. (the "Borrower") executed in favor of Orrstown Bank (the "Bank") a promissory note in the original amount of $2,100,000.00 bearing interest at an initial interest rate of 5% (the "Note'D. The Note is secured by, among other things, mortgages and assignments of rents on real property located at 1267 Allendale Road, Mechanicsburg, PA 17055; 39691 Hampton Lane, North Bethany, DE 19930; and 8 Foxfield Court, Mechanicsburg, PA 17050; life insurance policies described in a certain assignment of life insurance polices dated June 1, 2010; and inventory chattel, paper, accounts, equipment, general intangiblet and other assets of the Borrower. The Note is guaranteed by Robert L. Slagle, Susan E. DeRemer Slagle, and Lightstyles, Ltd. The a mounts owed as of December 2, 2011 are as follows: Principal: $2,076,817.15 Interest: $ 8,941.85 Loan Admin Fee $ 300.00 Legal Fees $ 3.000.00 Total $2,089,058.90 The per diem interest on the Note is $288.24. 1500 Market Street • Suite 3500E • Philadelphia, PA 19102-2101. 215-575-7000 • fax: 215-575-7200 84NW.dilworthlawcom . Cherry Hill, NJ . Harrisburg, PA • Washington, DC • Neptune, NJ • Wilmington, DE Ms. Susan B. DeRemer December 6, 2011 Page 2 On November 2, 2011, the Bank demanded repayment of the Note on or before December 2, 2011. To date that payment has not been received and the loan is in default. Pursuant to the terms of your commercial guaranty dated June 1, Orrstown Bank hereby demands that payment in full of the Note be made on or before December 28, 2011. Payment should be sent to: Orrstown Bank 2695 Philadelphia Avenue Chambersburg, PA 17201 Attention: Bradley Tanguay Partial payments will be accepted and credited against your accounts however, they will not relieve the guarantor of its obligations under the guaranty and this letter. Failure to pay in accordance with this letter shall cause a default under the guaranty and may cause the Bank to, without further notice to the Borrower or guarantors, take all appropriate action and institute all appropriate legal proceedings which the Bank deems necessary to assure full collection of the amount due on the Note and guaranties. These proceedings could include, but are not limited to, filing a civil action or confession of judgment proceeding against the Borrower or any of the guarantors. You will be responsible for legal fees incurred by the Bank in connection with the collection of such outstanding amounts. By delivering this letter, the Bank is not waiving any rights, powers or privileges granted to the Bank by the Note or the various other documents and instruments executed by the Borrower and others as collateral for the Note. The Bank hereby expressly reserves all of its rights with respect to enforcing any and all such rights, powers or privileges at any time in the future. In no event shall the Bank's delay in exercising, or its failure to exercise, any and all of the Bank's rights, powers, privileges or remedies, nor the Bank's partial exercise of the same, constitute a waiver or release of any of the Bank's rights, powers, privileges or remedies. - Sincerely, VI L Martin J. Weis MJW:lz 84319872 Exhibit "3B" 100% Recycled fiber 80% Post-Consumer R Z o C^?°o gj5 ^g+. ..n N ?. o rn, 'G ?d ?a in N ti CD (D •J Q z (rd i-? pv 11• Q. (D s `d C3. O N CN .y O LORI A ZIMMPRMAN 0.0 LBS LTR 1 OF 1 (215) 575.7097 7097 DILWORTH PAXSON • PHILADELPHIA 1500 MARKET STREET PHILADUPHU PA 19102 SHIP TO: MS. SUSAN B. DEREMER MS. SUSAN B. DEREMER 8 FOXFIELD COURT MECHANICSBURG PA 17050-7339 ?'• PA 171 9-10 ?o f? Y • UPS NEXT DAY AIR- TRACKING #: 1Z V69 SOR 24 9261 1560 BILLING: P/P SIGNATURE REQUIRED Client/Matter- 29S I V94996 AttomeyName: Mardn J. Weis GS116 )2 wxrv .-,,A70/ , [EL pt i? v v K F1 N C 0 rD N V) I m 0 w ro (A N $A H Z x CL - - - - o _ (A' D D 5 -' C6 ?'e e el M UPS: Tracking Information http://wwwapps.ups.com/WebT... Monday, March 05, 2012 United States New User I Log-In I Contact UPS I The UPS Stare ;Search Sub My UPS Shipping Tracking Freight Locations Support UPS Solutions Log-In for additional trackin details. Tracking Number Track 9 -- Other Tracking Options Tracking Detail 1ZV69SOR2492611560 Alternate Tracking Number 1LV5G50R1 29261 1 565 Pri Helc A Aj;-A II Updated: 03105/2012 4 41 P.M. Eastern Time Returning to Sender ....... .__. ...... ..._.._ i _ Last Location: Change Delivery P Harrisburg, PA, United States, Friday, 12116/2011 ???III Special Instructions: Request Status Updates n I Signature Required J Additional Information Shipped/Billed On; 12/06/2011 Type Package Shipping Information To. PHILADELPHIA, PA, US Shipped By UPS Next Day Air0 ` UPS MY moitt- TIRED OF GETTING .' ... - -----._.._. _.... ---------------- , THIS. Shipment Progress 'What's This ? i l .. _" Location Date Tlme Activity Harrisburg, PA, United States 12x1612011 4:49 P M The customer was not available on 3rd attempt. / Returned to shipper. Alternate Tracking Number j I J5950R1?92511565 Harrisburg. PA, United States 1210912011 6:45 P.M The customer was not available on 3rd attempt. / A postcard has been sent to the recipient requesting that j they contact UPS. j j 12/09/2011 9:11 A.M. The customer was not available on 3rd attempt. 1210912011 2:54 A.M. Out For Delivery j Harrisburg, PA, United States 12/08/2011 9.12 A.M. The customer was not available on the 2nd attempt. A 3rd j attempt will be made. l 12/08/2011 4:10 A.M. Out For Delivery j Harrisburg, PA, United Slates 12/0712011 9,23 A.M. The customer was not available on the 161 attempt. A 2nd attempt will be made. I j 121071'2011 743 A.M. Out For Delivery j i i 1210712011 5.15 A, M. Arrival Scan I I Philadelphia, PA, United States 12/07/2011 2:47 A M Departure Scan j 12/07/2011 12:01 A.M . Arrival Scan Philadelphia. PA, United States 12106/2011 11:22 P.M . Departure Scan 12/0612011 7:44 P.M. Origin Scan United States 12/05/2011 11:04 A.M Order Processed: Ready for UPS i Subscribe to UPS E-mail: Endere-n+ad address Siyn Up» Vle:v E?%:ma:r? „Q Feedback UPS Contact : Stu ,p rt Solutions for: Other UPS Sites: Online Suppoti Gel Started Healthcare Select a website j? E-mail UPS Reoister Small Business EFi Live Ch t O OQen a Shipping Acco unt r High Tech j `Call Customer ,Serwce Change Y our Dativerv ore.. WE VLOGISTICS' UPS: Tracking Information http://wwwapps.ups.com/WebT... Monday, March 05, 2012 Home About P Site i e investor s ar s ro r m UPS Global UPS Mobile PU S Bloa Service Terms ano CondiliM WebsiteTermsqf!jj Privacy Nolice .7 Your California Privacy Riohts O Protect Aaanst Fraud Copyright 0 1994.2012 United Parcel Service of America. Inc All tights reserved. Exhibit "4A" Dilworth PaxsonW Martin I Weis mweis@dilworthlaw.com December 6, 2011 VIA UPS OVERNIGHT MAIL LightStyles, Ltd Attn: Robert L. Slagle 1261 Claremont Road Carlisle, PA 17015 RE: Promissory Note dated June 1, 2010 [Loan No. 1332300301] Dear Mr. Slagle: This office represents Orrstown Bank in connection with the above referenced matter. On June 1, 2010, Marvin Window and Door Showplace, Inc. (the "Borrower") executed in favor of Orrstown Bank (the "Bank") a promissory note in the original amount of $2,100,000.00 bearing interest at an initial interest rate of 5% (the "Note"). The Note is secured by, among other things, mortgages and assignments of rents on real property located at 1267 Allendale Road, Mechanicsburg, PA 17055; 39691 Hampton Lane, North Bethany, DE 19930; and 8 Foxfield Court, Mechanicsburg, PA 17050; life insurance policies described in a certain assignment of life insurance polices dated June 1, 2010; and inventory chattel, paper, accounts, equipment, general intangibles and other assets of the Borrower. The Note is guaranteed by Robert L. Slagle, Susan E. DeRemer Slagle, and Lightstyles, Ltd. The amounts owed as of December 2, 2011 are as follows: Principal: $2,076,817.15 Interest: $ 8,941.85 Loan Admin Fee $ 300.00 Legal Fees $ 3,000.00 Total $2,089,058.90 The per diem interest on the Note is $288.24. 1500 Market Street • Suite 3500E • Philadelphia, PA 19102-2101. 715-575-7000 • fax: 215-575-7200 84mw.dilworthlawcom . Cherry Hill, NJ . Harrisburg, PA • Washington, DC • Neptune, NJ • Wilmington, DE Mr. Robert L. Slagle December 6, 2011 Page 2 On November 2, 2011, the Bank demanded repayment of the Note on or before December 2, 2011. To date that payment has not been received and the loan is in default. Pursuant to the terms of your commercial guaranty dated June 1, Orrstown Bank hereby demands that payment in full of the Note be made on or before December 28, 2011. Payment should be sent to: Orrstown Bank 2695 Philadelphia Avenue Chambersburg, PA 17201 Attention: Bradley Tanguay Partial payments will be accepted and credited against your accounts however, they will not relieve the guarantor of its obligations under the guaranty and this letter. Failure to pay in accordance with this letter shall cause a default under the guaranty and may cause the Bank to, without further notice to the Borrower or guarantors, take all appropriate action and institute all appropriate legal proceedings which the Bank deems necessary to assure full collection of the amount due on the Note and guaranties. These proceedings could include, but are not limited to, filing a civil action or confession of judgment proceeding against the Borrower or any of the guarantors. You will be responsible for legal fees incurred by the Bank in connection with the collection of such outstanding amounts. By delivering this letter, the Bank is not waiving any rights, powers or privileges granted to the Bank by the Note or the various other documents and instruments executed by the Borrower and others as collateral for the Note. The Bank hereby expressly reserves all of its rights with respect to enforcing any and all such rights, powers or privileges at any time in the future. In no event shall the Bank's delay in exercising, or its failure to exercise, any and all of the Bank's rights, powers, privileges or remedies, nor the Bank's partial exercise of the same, constitute a waiver or release of any of the Bank's rights, powers, privileges or remedies. Sincerely, Martin J. Weis MJW:lz 84319972 Exhibit "4B" v1 0. 1 La-,1111tb' LILLVLILLUL14Jlt Page 1 of 1 United States New User I Logan I Contact UPS I The UPS Store 'iie- - Sub My UPS Shipping Tracking Freight Locations Support UPS Solutions Trat3dng Number Track Lag-In for additional tracking details. Other Tracking Options r?r•.e.?.e?r?r_ Tracking Detail Pnitt Help A A A 1 ZV6950R2492672148 Updated, 0212212012 5:46 P.M. Eastern Time Delivered Shipping Information To: CARLISLE, PA, US Delivered On: Request Status Updates » M Shipped By . Wednesday, 1210712011 at 9:30 A. Left At: UPS Next Day Receiver Alr® Special Instructions: Signature Required f ups My cxarn Signed By: SCOTT TIRED OF Proof of Delivery GETTING THIS? Additional Information 12/06/2011 O i l n: ed ShippedlB l Type: Package Shipment Progress Whars This? Subscribe to UPS Email: Enfer a-ma/1 adUresS _ Slgn Up » View Examples Site Feedback Contact UPS Support Solutions for. Other UPS Sites: ,Q8rowse Online Suooort Gat Started Healthcare set" a websne Et 99 A +nail UPS RQgistef Small @yainess Live hat 0 Ow a Shipping Account a ft h Tech t Call Customer Service Change Your Delivery MMore.. WEQLQGISTICS` Hems About UPS 6114 GUI Investors Careen Pressroom S Globs d UPS Mobile UPS sloe Service Terms and Cgndidons Websile Tema of Use PrivacyNotice 7 Your California Privacy Riehte :7 Protect Intl Fraud Copyright ® 1994-2012 United Parcel Service of America, Mc. All rights reserved. http ://wwwapps.ups.com/W ebTracking/processReq uest?HTML Version=5.0&Requester=... 2/22/2012 rage t of 2 Weis, Martin J. (PHL) From: Zimmerman, Lori A. (PHL) Sent: Wednesday, December 07, 2011 11:07 AM To: Weis, Martin J. (PHL) Subject: FW: UPS Delivery Notification, Tracking Number 1ZV6950R2492572148 FYI From: UPS Quantum View (mailto:auto-notify@ups.com] Sent: Wednesday, December 07, 20119:52 AM To: Zimmerman, Lori A. (PHL) Subject: UPS Delivery Notification, Tracking Number IZV695OR2492572148 Discover more about UPS: Visit www.ups.com Sign Up For Additional E-Mail From UPS Read Compass Online UPS MY CH01cr WIN WHAT YOU WANT -: rAK1°: Nix purdiasa neae"a . ***Do not reply to this e-mail. UPS and Dilworth Paxson - Philadelphia will not receive your reply. At the request of Dilworth Paxson - Philadelphia, this notice is to confirm that the following shipment has been delivered. Important Delivery Information Tracking Number: 1ZV6950R2492572148 Delivery Date / 07-December-2011 / 9:30 Time: AM Delivery Location: RECEIVER Signed by: SCOTT Shipment Detail Ship To: Attn: Robert L. Slagle LightStyles, Ltd. 1261 CLAREMONT RD CARLISLE PA 17015 US Number of Packages: 1 2/22/2012. Vage 2 of "2 UPS Service: NEXT DAY AIR Shipment Type: Letter Reference Number 1: 29512/94996 Reference Number 2: Martin J. Weis Reference Number 3: Orrstown/Slagle -_2@@2@@2RorYbu6 ® 2011 United Parcel Service of America, Inc. UPS, the UPS brandmark, and the color brown are trademarks of United Parcel Service of America, Inc. All rights reserved. For more information on UPS's privacy practices, refer to the UPS Privacy Policy. Please do not reply directly to this e-mail. UPS will not receive any reply message. For questions or comments, visit Contact UPS. This communication contains proprietary information and may be confidential. If you are not the intended recipient, the reading, copying, disclosure or other use of the contents of this e-mail is strictly prohibited and you are instructed to please delete this e-mail immediately. Privacy Policy Contact UPS 2/22/2012 • COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF FRANKLIN Bradley Tanguay, being duly sworn according to law, deposes and says that he is Vice President, Special Assets, Orrstown Bank, Plaintiff named herein; that as such he is authorized to take this Affidavit on its behalf; that the facts set forth in the foregoing Answer and New Matter of Plaintiff Orrstown Bank to Petition of Susan B. DeRemer to Strike Off or Open Judgment are true and correct to the best of his knowledge, information and belief. Sworn to and Subscribed Before me this M day of Al QV C? , 2012. CAW_ Notary Public 87656464 Bradley anguay Vice President 6 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Christiana R. Timmons, Notary Public Chambersburg Boro, Franklin County My Commission Expires March 3, 2014 Member, Pennsylvania Association of Notaries CERTIFICATE OF SERVICE I certify that I am this day serving a copy of the foregoing document upon the persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, Harrisburg, Pennsylvania, with first-class postage, prepaid, as follows: Keith Brenneman, Esquire Snelbaker & Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055 Dated: ©- 1 Z Eliza h J. Goldstein Pa. I.D. # 73779 Dilworth Paxson, LLP 112 Market Street, Suite 800 Harrisburg, PA 17101 Telephone (717) 213-4106 Attorneys for Orrstown Bank 88067111 ORRSTOWN BANK, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SUSAN B. DEREMER, DEFENDANT NO. 12-143 CIVIL ORDER OF COURT AND NOW, this 22"d day of March, 2012, upon consideration of the Defendant's Petition to Strike Off or Open Judgment, the Plaintiff's Answer and New Matter thereto, the arguments of counsel, and a careful analysis of the holding in Stein v. Penncrest Construction Corp., 421 A.2d 1074 (Pa.Super. 1980); IT IS HEREBY ORDERED AND DIRECTED that the Defendant's Petition to Strike Off or Open Judgment is DENIED. By the Court, ?k -? QA M. L. Ebert, Jr., J. ? Elizabeth Goldstein, Esquire Attorney for Plaintiff Keith Brenneman, Esquire Attorney for Defendant bas e-s ma, led ,t ::u M yC/31- ?/ y l1 1 y? ?•..J 1 Y ?. at " Orrstown Bank : IN THE COURT OF COMMON PLEAS v. : CUMBERLAND COUNTY, PENNSYLVANIA Susan B. Deremer a/k/a Susan Deremer Slagle, Defendant : NO. 2012-143 m roar PRAECIPE TO THE PROTHONOTARY: Please mark the above judgment as satisfied for the property known as 8 Foxfield Court as outlined in the attached Exhibit. Respectfully Submitted; Martin J. Weis, Esquire $4 sv P/v4b e#-257/6C �axs®� , f2 7F93 MARTIN J. WEIS, ESQUIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION NO. 51379 DILWORTH PAXSON LLP 1500 MARKET STREET, SUITE 3500E PHILADELPHIA, PENNSYLVANIA 19102-2101 (215) 575-7000 ORRSTOWN BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. CIVIL DIVISION SUSAN B. DEREMER a/k/a SUSAN DEREMER NO. 2012-143 SLAGLE RELEASE OF LIEN OF JUDGMENT TO THE PROTHONOTARY: Plaintiff in the above-stated action, at the request of Defendant and for and in consideration of the sum of Ten Dollars ($10.00) to us in hand paid by Defendant at the time of execution hereof, the receipt of which is hereby acknowledged, do for ourselves, our successors and assigns, covenant, promise, and agree, to and with the Defendant, their heirs and assigns, by these presents, that we will not at any time hereafter sell or dispose of, attach or levy upon, or claim or demand the premises known as 8 Foxfield Court, Mechanicsburg, Cumberland County, Pennsylvania, more fully described in Exhibit "A" attached hereto, with the appurtenances or any part thereof by virtue of the said judgment, so that the said Defendant, their heirs and assigns, shall and may hold the same, free and clear of and from the lien of the said judgment; provided, 11292125_1 however, that nothing herein contained shall invalidate the lien, indebtedness or security of the said judgment upon any other estate of Defendant. Dilworth Paxson L4,P Date: September(, 2013 By: pii s Man J. s, Esquire Attorney for Plaintiff 2 11292125_1 • • LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land situate in Silver Spring Township,Cumberland County, Pennsylvania,more particularly bounded and described in accordance with the Major Final Subdivision Plan for The Peninsula(Phase 1),prepared by H.Edward Black&Associates,P.C.,more particularly bounded and described as follows,to wit: BEGINNING at a concrete monument on the western right-of-way line of Foxfield Court at the dividing line between Lot-110 and Lot-109 on the hereinabove mentioned subdivision plan;thence along said dividing line between Lot-110 and Lot-109,South 73 degrees 46 minutes 42 seconds West,a distance of 629.47 feet to an iron pin along the eastern right-of-way line of Conodoguinet Creek;thence along the eastern right-of- way line of Conodoguinet Creek North 10 degrees 50 minutes 57 seconds West,a distance of 511 feet to an iron pin along potherb lands now or formerly of Sample Bridge Associates;thence along the lands now or formerly of Sample Bridge Associates North 81 degrees 30 minutes 00 seconds East,a distance of 428.30 feet to an iron pin at the dividing line between Lot 108 and Lot 109;thence along said dividing line.between Lot-I 08.and Lot- 109 South 40 degrees 19 minutes 46 seconds East,a distance of 436.89 feet to a concrete monument along the western right-of-way line of Foxfield.Court;thence along the western right-of-way line of Foxfield Court on a curve to the left having a radius of 50 feet an arc length of 65 feet to a concrete monument at the dividing line between Lot-109 and Lot-110;the point and place of BEGINNING. CONTAINING 5.9597 acres more or less. BEING LOT-109 on the hereinabove mentioned Subdivision Plan for The Peninsula(Phase 1)as • recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 65 at'Page 28. BEING the same premises which Sample Bridge Associates by its deed dated January 13, 1994 and recorded on January 24, 1994,in Deed Book"T",Volume 36,Page 772,in the Office of the Recorder of Deeds in and for Cumberland County,Pennsylvania,granted and conveyed unto Robert L.Slagle and Susan D.Slagle, husband and wife,the Borrowers and Mortgagors herein. • • •