HomeMy WebLinkAbout04-478301
TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I. D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V.
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO. dLI.L/
ENTRY OF JUDGMENT BY CONFESSION
AND ASSESSMENT OF DAMAGES
Pursuant to the Complaint in Confession of Judgment filed in the within action
and the Warrant of Attorney attached hereto, judgment is hereby entered against the
Defendant, jointly and severally.
DAMAGES ARE ASSESSED AS FOLLOWS:
Unpaid principal balance under the Note/Loan
Agreement dated April 30, 2003 as of
July 6, 2004 $444,454.49
Late fees from July 6, 2004 1,160.76
$445,615.25"
'Together with interest accruing at the rate in the Note/Loan
Agreement from July 6, 2004, attorneys' fees, and costs of this action
(to be determined)
77956.1 P HO I
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0
TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
V.
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
CIVIL DIVISION
NO.
Defendant.
ENTRY OF APPEARANCE
PRAECIPE FOR ASSESSMENT OF DAMAGES
AND CONFESSION OF JUDGMENT
TO THE PROTHONOTARY:
Kindly enter our appearance for and on behalf of the Defendant above
named.
Pursuant to the authority contained in the Warrant of Attorney separately
set forth in the Loan Agreement dated April 30, 2003, a true and correct copy of
which is attached as Exhibit A to the Complaint filed in this action, we hereby
appear for the Defendant in this matter, HealthCore, LLC, and confess judgment
authorized, in favor of the Plaintiff and against the Defendant, as follows:
DAMAGES ARE ASSESSED AS FOLLOWS:
Unpaid principal balance under the Note/Loan
Agreement dated April 30, 2003 as of
July 6, 2004 $444,454.49
Late fees from July 6, 2004 1,160.76
$445,615.25*
*Together with interest accruing at the rate in
the Note/Loan Agreement from July 6, 2004, attorneys' fees, and
costs of this action (to be determined)
Dated: f --L-7,0V
71973.1
TU (ER ARENSBERG, P.C.
F. taphenson tthes
' V 7
PA D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
Attorneys for Plaintiff,
The Legacy Bank
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t"i
61
TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I. D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
V. CIVIL DIVISION
HEALTHCORE, LLC NO.
47 West Pomfret Street
Carlisle, PA 17013,
Defendant.
COMPLAINT IN CONFESSION OF JUDGMENT
Plaintiff, The Legacy Bank (the "Bank"), by and through its attorneys,
Tucker Arensberg, P.C., files this Complaint for judgment by confession pursuant to
Pennsylvania Rules of Civil Procedure 2950-2956 and, in support hereof, states as
follows:
1. The Bank is a national banking association with an address at 2600
Commerce Drive, Harrisburg, Pennsylvania 17110.
2. Defendant, HealthCore, LLC, is a Pennsylvania corporation with a last
known address at 47 West Pomfret Street, Carlisle, Pennsylvania 17013.
3. The Defendant executed that certain Note/Loan Agreement dated April 30,
2003 (the "Note") pursuant to which the Defendant agreed to all terms and of payment
and all other conditions thereunder. True and correct copies of the Note/Loan
Agreements are attached hereto and incorporated herein as Exhibits "A".
4. The Note authorized the confession of judgment against the Defendant.
5. As a result (among other things) Borrower's failure to pay certain amounts
as and when due under the Agreements, events of default occurred under the
Agreements.
6. Pursuant to the terms of the Agreements, upon the occurrence of an event
of default, the Bank was authorized to declare all amounts payable under the
Agreements to be immediately due and payable.
7. On or about September 17, 2004, the Bank sent letters to Borrower,
notifying the Borrower of the occurrence of events of default under the Agreements (the
"Default Letters") and declaring the unpaid principal amount of the Agreements, interest
accrued thereon, and all other amounts owing under the Agreements to be immediately
due and payable in full. True and correct copies of the Default Letter are attached
hereto and incorporated herein by reference as Exhibit "B".
8. Notwithstanding default and demand, the Borrower has not paid the full
amounts owed to the Bank under the Agreement.
9. Pursuant to the terms of the Agreements, upon the occurrence of an event
of default under the Note, the Bank may appear for and confess judgment against the
Defendant for the amounts due and owing under the Note.
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10. Under the terms of the Note, the Bank is entitled to recover from the
Defendant the costs of any suit, including attorneys' fees.
11. Under the terms of the Note, the Defendant agreed that the Courts of
Common Pleas of the Commonwealth of Pennsylvania and any United States District
Court in Pennsylvania shall have jurisdiction with respect to matters involving the Note.
12. As of September 10, 2004, the amounts due and owing by the Defendant
to the Bank under the Note are as follows:
Unpaid principal balance under the Note/Loan
Agreement dated April 30, 2003 as of
July 6, 2004 $444,454.49
Late fees from July 6, 2004
1,160.76
$445,615.25*
*Together with interest accruing at the rate in the Note/Loan
Agreement from July 6, 2004, attorneys' fees, and costs of
this action (to be determined)
13. The Note has not been assigned by the Bank.
14. The Bank's claims against the Defendant are not based upon a residential
mortgage and Act 6 does not apply.
15. No judgment has been entered on the Note in any jurisdiction.
16. The confession of judgment provision appearing in each of the Notes is
less than twenty (20) years old.
17. Judgment in favor of the Bank and against the Defendant is not being
entered against a natural person in a consumer credit transaction.
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18. Judgment in favor of the Bank and against the Defendant as demanded is
authorized by the confession of judgment provisions contained in the Note.
WHEREFORE, the Bank, as authorized by the Warrant of Attorney
contained in the Note, hereby demands that judgment by confession be entered in its
favor and against the Defendant, in the amount of $445,615.25, plus interest accruing
after July 6, 2004, plus costs and attorneys' fees and requests such other and further
relief as the Court may deem proper.
TU¢kER ARENSBERG, P.C.
V\\-I?
F. St phenson Matthes
P I. . No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
Attorneys for Plaintiff,
Dated: f -zz-vy The Legacy Bank
71974.1
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TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V.
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO.
VERIFICATION
Don Signor hereby states that he is a Loan Review Officer of The Legacy Bank,
and verifies that the statements made in the foregoing Complaint In Confession of
Judgment are true and correct to the best of his knowledge, information and belief. The
undersigned understands that the statements made therein are made subject to
penalties of 18 Pa. Cons. Stat. Ann. §4904 relating to unsworn falsification to
authorities.
Dated: y/z?a `f
71975.1
Don Signor, Loan view Officer
The Legacy Bank
CERTIFICATE OF SERVICE
AND NOW, this 2 3d day of 4-&*& , 2004, I, Dawn T. Heilman,
Legal Secretary to F. Stephenson Matthes, Esquire, for the firm of Tucker Arensberg,
P.C., hereby certify that I have this day served a true and correct copy of the within
document, by mailing same by U.S. Mail, Certified Return Receipt Requested, postage
prepaid, addressed as follows:
HealthCore, LLC
47 West Pomfret Street
Carlisle, PA 17013
Dawn T. Heilman
72101.1
OS Emil Busium Administration
0
SBA Loan # GP 626 380 40 09 HBG
SBA Loan Name HealthCore, LLC
Date April 30, 2003
Loan Amount 500,000.00
Interest Rate WSJ Prime+2.75%
Borrower
Operating
Company
HealthCore, LLC
Lender The Legacy Bank
1. PROMISE TO PAY:
In return for the Loan, Borrower promises to pay to the order of Lender the amount of
FIVE HUNDRED THOUSAND AND NO/100
interest on the unpaid principal balance, and all other amounts required by this Note.
2. DEFINITIONS:
"Collateral" means any property taken as security for payment of this Note or any guarantee of this Note.
"Guarantor" means each person or entity that signs a guarantee of payment of this Note.
"Loan" means the loan evidenced by this Note.
"fLoan Documents" means the documents related to this loan signed by Borrower, any Guarantor, or anyone who
pledges collateral.
"SBA" means the Small Business Administration, an Agency of the United States of America.
U.S. Small Business Administration
NOTE
no
Dollars,
SBA Form 147 (06/03/02) Version 4.1 Page 1/6
Bankers Systems, Inc., St. Cloud, MN
3. PAYMENT TERMS:
Borrower must make all payments at the place Lender designates. The payment terms for this Note are:
The interest rate on this Note will fluctuate. The initial interest rate is 7.500% per year. This initial rate is the prime
rate on the date SBA received the loan application, plus 2.75%. The initial interest rate must remain in effect until
the first change period begins.
\I Borrower must pay principal and interest payments of $7,547.00 every month, beginning one month from the
month of initial disbursement on this Note; payments must be made on the same day as the date of initial
disbursement nn this Note in the months they are due.
Lender will apply each installment payment first to pay interest accrued to the day Lender receives the payment,
then to bring principal current, then to pay any late fees, and will apply any remaining balance to reduce principal.
The interest rate will be adjusted quarterly (the "change period").
The "Prime Rate" is the prime rate in effect on the first business day of the month in which an interest rate change
occurs, a published in the Wall Street Joumal on the next business day.
The adjusted interest rate will be 2.75% above the Prime Rate. Lender will adjust the interest rate on the first
calendar day of each change period. The change in interest rate is effective on that day whether or not Lender
gives Borrower notice of the change. The initial interest rate must remain in effect until the first change period
begins.
Lender must adjust the payment amount at least annually as needed to amortize principal over the remaining term
of the note.
If SBA purchases the guaranteed portion of the unpaid principal balance, the interest rate becomes fixed at the
rate in effect at the time of the earliest uncured payment default. If there is no uncured payment default, the rate
becomes fixed at the rate in effect at the time of purchase.
All remaining principal and accrued interest is due and payable 7 years from date of Note.
Late Charge: If a payment on this Note is more than 10 days late, Lender may charge Borrower a late fee of up to
5% of the unpaid portion of the regularly scheduled payment.
Loan Prepayment:
Notwithstanding any provision in this Note to the contrary:
Borrower may prepay this Note. Borrower may prepay 20 percent or less of the unpaid principal balance at any
time without notice. If Borrower prepays more that 20 percent of the Loan and the Loan has been sold on the
secondary market, Borrower must:
a. Give Lender written notice:
b. Pay all accrued interest; and
c. If the prepayment is received less than 21 days from the date Lender receives the notice, pay an amount equal
to 21 days interest from the date Lender receives the notice, less any interest accrued during the 21 days and paid
under subparagraph b., above.
SBA Form 147 (06103/02) Version 4.1 Page 2/6
Bankers Systems, Inc., St. Cloud, MN
4. DEFAULT:
Borrower is in default under this Note if Borrower does not make a payment when due under this Note, or if Borrower
or Operating Company:
A. Fails to do anything required by this Note and other Loan Documents;
B. Defaults on any other loan with Lender;
C. Does not preserve, or account to Lender's satisfaction for, any of the Collateral or its proceeds;
D. Does not disclose, or anyone acting on their behalf does not disclose, any material fact to Lender or SBA;
E. Makes, or anyone acting on their behalf makes, a materially false or misleading representation to Lender or SBA;
F. Defaults on any loan or agreement with another creditor, if Lender believes the default may materially affect
Borrower's ability to pay this Note;
G. Fails to pay any taxes when due;
H. Becomes the subject of a proceeding under any bankruptcy or insolvency law;
1. Hasa receiver or liquidator appointed for any part of their business or property;
J. Makes an assignment for the benefit of creditors;
K. Has any adverse change in financial condition or business operation that Lender believes may materially affect
Borrower's ability to pay this Note;
L. Reorganizes, merges, consolidates, or otherwise changes ownership or business structure without Lender's prior
written consent; or
M. Becomes the subject of a civil or criminal action that Lender believes may materially affect Borrower's ability to
pay this Note.
5. LENDER'S RIGHTS IF THERE IS A DEFAULT:
Without notice or demand and without giving up any of its rights, Lender may:
A. Require immediate payment of all amounts owing under this Note;
B. Collect all amounts owing from any Borrower or Guarantor;
C. File suit and obtain judgment;
D. Take possession of any Collateral; or
E. Sell, lease, or otherwise dispose of, any Collateral at public or private sale, with or without advertisement.
6. LENDER'S GENERAL POWERS:
Without notice and without Borrower's consent, Lender may:
A. Bid on or buy the Collateral at its sale or the sale of another lienholder, at any price it chooses;
B. Incur expenses to collect amounts due under this Note, enforce the terms of this Note or any other Loan
Document, and preserve or dispose of the Collateral. Among other things, the expenses may include payments
for property taxes, prior liens, insurance, appraisals, environmental remediation costs, and reasonable attorney's
fees and costs. If Lender incurs such expenses, it may demand immediate repayment from Borrower or add the
expenses to the principal balance;
C. Release anyone obligated to pay this Note;
D. Compromise, release, renew, extend or substitute any of the Collateral; and
E. Take any action necessary to protect the Collateral or collect amounts owing on this Note.
SBA Form 147 (06/03/02) Version 4.1 Page 316
Bankers Systems, Inc., St. Cloud, MN
7. WHEN FEDERAL LAW APPLIES:
When SBA is the holder, this Note will be interpreted and enforced under federal law, including SBA regulations.
Lender or SBA may use state or local procedures for filing papers, recording documents, giving notice, foreclosing
liens, and other purposes. By using such procedures, SBA does not waive any federal immunity from state or local
control, penalty, tax, or liability. As to this Note, Borrower may not claim or assert against SBA any local or state law
to deny any obligation, defeat any claim of SBA, or preempt federal law.
8. SUCCESSORS AND ASSIGNS:
Under this Note, Borrower and Operating Company include the successors of each, and Lender includes its successors
and assigns.
9. GENERAL PROVISIONS:
A. All individuals and entities signing this Note are jointly and severally liable.
B. Borrower waives all suretyship defenses.
C. Borrower must sign all documents necessary at any time to comply with the Loan Documents and to enable
Lender to acquire, perfect, or maintain Lender's liens on Collateral.
D. Lender may exercise any of its rights separately or together, as many times and in any order it chooses. Lender
may delay or forgo enforcing any of its rights without giving up any of them.
E. Borrower may not use an oral statement of Lender or SBA to contradict or alter the written terms of this Note.
F. If any part of this Note is unenforceable, all other parts remain in effect.
G. To the extent allowed by law, Borrower waives all demands and notices in connection with this Note, including
presentment, demand, protest, and notice of dishonor. Borrower also waives any defenses based upon any claim
that Lender did not obtain any guarantee; did not obtain, perfect, or maintain a lien upon Collateral; impaired
Collateral; or did not obtain the fair market value of Collateral at a sale.
SBA Form 147 (06/03/02) Version 4.1 Page 4/6
Bankers Systems, Inc., St. Cloud, MN
10. STATE-SPECIFIC PROVISIONS:
WARRANT OF AUTHORITY TO CONFESS JUDGEMENT. Upon default, in addition to all other remedies and rights available to
you, by signing below I irrevocably authorize the prothonotary, clerk, or any attorney to appear in any court of record having
jurisdiction over this matter and to confess judgment against me at any time without stay of execution. I waive notice, service of
process, and process. I agree and understand that judgment may be confessed against me for any unpaid principal, accrued
charges due on this Note, plus collection costs and reasonable attorneys' fees up to 15 percent of the judgement The exercise of
the power to confess judgment will not exhaust this warrant of authority to understand that my property may be seized without prior
notice to satisfy the debt owed. I knowingly, intentionally, and voluntarily waive any and all constitutional rights I have to
pre-deprivation notice and hearing under federal and state laws and fully understand the consequences of this waiver.
immediately below, I agree to the terms of the CONFESSION OF JUDGEMENT section.
yne"Jaer, Member
SBA Form 147 (06/03102) Version 4.1
?s03
Date
?6-Kd 3
Date
Page 5/e
Bankers Systems, Inc., St. Cloud, MN
11. BORROWER'S NAME(S) AND SIGNATURE(S):
By signing below, each individual or entity becomes obligated under this Note as Borrower.
HealthCore, LLC
?! _.. April 30, 2003
n e m, e e
April 30, 2003
Krist Baer, Mem er /
SBA Fonn 147 (06103/02) version 4.1 Page 6/6
Bankers Systems, Inc., St. Cloud, MN
TUCKER ARENSBERG
Attorneys
September 16, 2004
VIA CERTIFIED MAIL; RETURN RECEIPT REQUESTED
NO. 7002 2410 0001 2367 2348 AND FIRST CLASS MAIL
Jenine J. Kerr
Krista K, Baer
HealthCore, LLC
47 West Pomfret Street
Carlisle, PA 17013
F. Stephenson Matthes
smatthes@tuckerlaw.com
RE: Promissory Note dated April 30, 2003 (SBA Loan) in Principal Amount of
$500,000 Between HealthCore, LLC and The Legacy Bank
Notice of Default and Demand for Payment
Dear Ms. Kerr and Ms. Baer:
This office represents The Legacy Bank ("Legacy" or "Lender").
Reference is made to that certain Promissory Note dated April 30, 2003 (the "Note") in
the principal amount of $500,000, which was executed and delivered to Legacy by
HealthCore, LLC ("Borrower"). Reference is further made to that certain Commercial
Security Agreement dated April 30, 2003 (the "Security Agreement"), which was
executed and delivered by the Borrower to Legacy.
The paragraph of the Note entitled "DEFAULT" provides, in part, that Borrower will be in
default if "Borrower does not make a payment when due under this Note or if Borrower
or Operating Company: (a) fails to do anything required by this Note and other Loan
Documents; (b) defaults on any other loan with Lender; (c) does not preserve or account
to Lender's satisfaction for, any of the Collateral or its proceeds; (d) fails to pay any
taxes when due; ... ". The Note provides that upon default, Lender may "(a) require
immediate of all amounts owing under this Note; (b) collect all amounts owing from any
Borrower or Guarantor; (c) file suit and obtain judgment; (d) take possession of any
Collateral; or (e) sell, lease or otherwise dispose of any Collateral at public or private
sale with or without advertisement."
Borrower is presently in default for numerous reasons including a failure to make
payments when due on several loan obligations to Legacy, as well as for failing to make
tax payments when due.
Pursuant to the direction of Legacy Bank, we hereby notify.you that Legacy Bank
declares the entire balance under the Notes immediately due and payable and demands
immediate payment of all principal, interest, and fees, currently $444,454.49, together
with accruing interest, attorneys' fees and other expenses. This balance is current as of
September 15, 2004, but does not include attorneys' fees and costs. For a complete
breakdown of the same, please contact the undersigned.
Tucker Arensberg, P.C. 111 North Front Street P.O. Box 889 Harrisburg,PPA 17108 www.tuckerlaw.com
r r'te' p. 800.257.4121 p. 717.234.4121 f.71 32.6802
TUCKER ARENSBERG
A t t 0 r n a y s
Janine J. Kerr
Krista K. Baer
September 16, 2004
Page 2
Payment should be made by cashier's check or wire transfer to The Legacy Bank, 2600
Commerce Drive, Harrisburg, PA 17110. The Legacy Bank reserves all rights and
remedies that it has under the Note, any other loan documents executed in connection
with the Note, any other loan documents by the Borrower, any third party obligor, any
pledgor, any guarantor and/or at law or in equity.
Thank you for your immediate attention to this matter.
Very truly yours,
TIyCItER ARENSBERG, P.C.
F. Stephenson Matthes
FSM/dth
cc: Janine J. Kerr
Ronald W. Baer
Krista K. Baer
W&C Realty & Holdings, L.P.
HealthCore of Maryland, LLC
HealthCore of Ohio, LLC
71852.1
TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V.
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO.
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS.
Don Signor, being duly sworn according to law, deposes and says that he is a
Loan Review Officer of The Legacy Bank, that he is duly authorized to make this
affidavit on behalf of Plaintiff; that the facts set forth in the foregoing Complaint In
Confession Of Judgment are true and correct to the best of his information and beli
r.
and that the Note (as defined in the Complaint) which is attached as an Exhibit to t
61
TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V.
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 170131
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO.
6-
TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V.
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO.
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS,
Don Signor, being duly sworn according to law, deposes and says that he is a
Loan Review Officer of The Legacy Bank, that he is duly authorized to make this
affidavit on behalf of Plaintiff; that the facts set forth in the foregoing Complaint In
Confession Of Judgment are true and correct to the best of his information and belief;
and that the Note (as defined in the Complaint) which is attached as an Exhibit to the
Complaint In Confession Of Judgment is a true and correct copy of the original
executed by the Defendant.
Don Signor, Lo n Revi Officer
The Legacy Bank
Sworn to and subscribed before me
this,/,W.?- day of September, 2004.
No Public.
Ndit, seal
sus. ? oar sem?a, rotary PubAc
Cxy Of riaxrWxn, Dauphin cou7ly
W comrAsim Expires Apr. 9, 2007
?IMtW. PWVWA" ANOCW nOfNOWO
-2-
61
TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V.
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO.
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS
Before me, the undersigned Notary Public, in and for said County and State,
personally appeared Don Signor, Loan Review Officer of The Legacy Bank, Plaintiff
herein who, as an authorized representative thereof, being duly sworn according to law,
deposes and says that the Defendant is not in the military service of the United States
of America, to the best of his knowledge, information and belief.
/N ?• C
Don Signor, oan iew Officer
The Legacy Bank
Sworn to,-AN subscribed before
e isA day of September, 2004.
Not M Seal
Dwnaft Bathe, NoWy NOC
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TUCKER ARENSBERG. P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V.
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO.
AFFIDAVIT OF INCOME
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS
Don Signor, being duly sworn according to law, deposes and says that he is a
Loan Review Officer of The Legacy Bank; that he is a duly authorized representative of
Plaintiff; and that to the best of his knowledge, information and bel' f the income of the
Defendant is in excess of $10,000.00 per year.
Don Signor, Lo n Revi Officer
The Legacy Bank
Swor t and Subscribed before me
t ' ay of September, 2004.
Notary Public
71977.1 Niatli1a! Seal
Darr"Ia Bete, NDt"- R.bk
City Of Hwdxirg, Da#w CW*
my Oan'prosinn Expires Apr. 9, 2007
Mmtlr,P mAfto elona N*Aft
0-
TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I. D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V.
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO.
AFFIDAVIT OF NONAPPLICABILITY OF
GOODS AND SERVICES INSTALLMENT SALES ACT
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS
Don Signor, being duly sworn according to law, deposes and says that he is a Loan
Review Officer of The Legacy Bank; that he is a duly authorized representative of Plaintiff; that
the Complaint In Confession Of Judgment does not arise out of a retail installment sale,
contract, or account, as defined under the Goods and Services Installment Sales Act, 69 Pa.
Stat. Ann. §1101, et seg.; and that the foregoing facts are true and come to the best of his
knowledge, information and belief.
Don Signor, Loan 1tevie fficer
The Legacy Bank
Swo to and Subscribed before??jjme,, ?
t dayo S8cepte ri f 0? C r
.S
No Public
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TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V.
HEALTHCORE,LLC
47 West Pomfret Street
Carlisle, PA 17013,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO.
AVERMENT OF DEFAULT
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS.
Don Signor, being duly sworn according to law, deposes and says that he is a Loan
Review Officer of The Legacy Bank, that he is a duly authorized representative of Plaintiff; that
the Defendant executed the Note (as defined in the Complaint), true and correct copies of which
are attached to the Complaint; that the Defendant is in default under the Note; and that there is
$445,615.25 due and owing under the Note as of Septr 10, 2004
Don Signor, LoarfRevi Officer
The Legacy Bank
an
tto
d subscribed before me
day of September, 2004.
t?
ublic. 71979.1
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TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V.
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO.
AFFIDAVIT OF COMMERCIAL TRANSACTION
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS
Don Signor, being duly sworn according to law, deposes and says that he is a
Loan Review Officer of The Legacy Bank; that he is a duly authorized representative of
Plaintiff; that the underlying transaction relative to this Complaint In Confession Of
Judgment is a commercial transaction to the best of his knowledge -information and
belief.
Don` Signor, Low Re ' Officer
The Legacy Bank
Sworn to and subscribed before
m t i? day of Septejpber, 2004.
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6
TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
Plaintiff,
V,
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO.
Defendant.
ACT 105 OF 2000 NOTICE
A JUDGMENT HAS BEEN ENTERED AGAINST YOU BY CONFESSION OF
JUDGMENT.
PURSUANT TO 42 PA. C.S.A. §2737.1, IF YOU WERE INCORRECTLY IDENTIFIED
AS A DEFENDANT IN THE COMPLAINT IN CONFESSION OF JUDGMENT, YOU MAY BE
ENTITLED TO COSTS AND REASONABLE ATTORNEY FEES AS DETERMINED BY THE
COURT.
YOU MAY TAKE ACTION TO STRIKE THE JUDGMENT BY FOLLOWING THE
PROCEDURE IN RULE 2959 WHICH IS AS FOLLOWS:
Pennsylvania Rule of Civil Procedure 2959 - Strikinq Off Judgment.
(a)(1) Relief From a judgment by confession shall be sought by petition. Except as
provided in subparagraph (2), all grounds for relief whether to strike off the judgment or to open it
must be asserted in a single petition. The petition may be filed in the county in which the judgment
was originally entered, in any county to which the judgment has been transferred or in any other
county in which the sheriff has received a writ of execution directed to the sheriff to enforce the
judgment.
(2) The ground that the waiver of the due process rights of notice and hearing was not
voluntary, intelligent and knowing shall be raised only
(i) in support of a further request for a stay of execution where the court has
stayed execution despite the timely filing of a petition for relief from the judgment and the
presentation of prima facie evidence of a defense; and
(ii) as provided by Pennsylvania Rule of Civil Procedure 2958.3 or Rule 2973.3.
(3) If written notice is served upon the petitioner pursuant to Rule 2956.1(c)(2) or Rule
2973.1(c), the petition shall be filed within thirty days after such service. Unless the defendant
can demonstrate that there were compelling reasons for the delay, a petition not timely filed
shall be denied.
(b) If the petition states prima facie grounds for relief the court shall issue a rule to show
cause and may grant a stay of proceedings. After being served with a copy of the petition the
plaintiff shall file an answer on or before the return day of the rule. The return day of the rule
shall be fixed by the court by local rule or special order.
(c) A party waives all defenses and objections which are not included in the petition or
answer.
(d) The petition and the rule to show cause and the answer shall be served as provided
in Rule 440.
(e) The court shall dispose of the rule on petition and answer, and on any testimony,
depositions, admissions and other evidence. The court for cause shown may stay proceedings
on the petition insofar as it seeks to open the judgment pending disposition of the application to
strike off the judgment. If evidence is produced which a jury trial would require the issues to be
submitted to the jury the court shall open the judgment.
(f) The lien of the judgment or of any levy or attachment shall be preserved while the
proceedings to strike off or open the judgment is pending.
ARENSBERG, P.C.
Dated and Served:
September, 2004
By Certified Mail
Return Receipt Requested
71951.1
F. S ep en% MdttNes
PA I. No. 408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
Attorneys for Plaintiff,
The Legacy Bank
-2-
TUCKER ARENSBERG, P.C.
By: F. Stephenson Matthes
PA I.D. No. 67408
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Telephone: 717-234-4121
Facsimile: 717-232-6802
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
T
HEALTHCORE, LLC
47 West Pomfret Street
Carlisle, PA 17013,
CIVIL DIVISION
NO. 014 - u7-83
Defendant.
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby
notified that a JUDGMENT BY CONFESSION has been entered against you in the
above-captioned proceeding. Copies of all documents that have been filed with the
Prothonotary in support of the Confession of Judgment are attached hereto.
If you have any questions concerning this Notice, please call, F. Stephenson
Matthes, Esquire, at (717) 234-4121.
PR04G OT 7
71953.1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THE LEGACY BANK,
2600 Commerce Drive,
Harrisburg, PA 17110
Plaintiff,
vs.
HEALTHCORE, LLC,
47 West Pomfret Street
Carlisle, PA 17013,
Defendant,
and
CITIZENS BANK,
COMMUNITY BANK,
M&T BANK, and
"_--CAPITACTEMPFl7NIIS;'IM., Y6
Garnishees.
Wit( NO - r)cwc
'• vLt 5?..e.e s,
CIVIL DIVISION
NO. 04-4783
PRAECIPE FOR WRIT OF EXECUTION
UPON CONFESSION OF JUDGMENT
Filed on behalf of:
The Legacy Bank, Plaintiff
CODE:
Counsel of Record for This Party:
F. Stephenson Matthes
PA. I.D. NO. 67408
TUCKER ARENSBERG, P.C.
Firm #287
111 North Front Street
P.O. Box 1389
Harrisburg, PA 17110
p. 717.234.4121
CYTA? -6f-
IN THE COURT OF COMMONS PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
CIVIL DIVISION
Plaintiff,
vs.
HEALTHCORE, LLC,
47 West Pomfret Street,
Carlisle, PA 17013,
Defendant,
and
CITIZENS BANK,
COMMUNITY BANK,
M&T BANK, and
CAPITAL TEMPFUNDS, INC.,
Garnishees.
NO. 04-4783
PRAECIPE FOR WRIT OF EXECUTION
UPON CONFESSION OF JUDGMENT
To the Prothonotary:
Issue writ of execution in the above matter,
(1) directed to the Sheriff of Cumberland County;
(2) against, Healthcore, LLC, Defendant;
(3) and against Citizens Bank, Community Bank, M&T (Bank,
St--? A-r 4c-pwb 5)+ r For- ADD"JXts
Garnishees;
(4) and index this writ
(a) against Healthcore, LLC, Defendant;
(b) and against Citizens Bank, Community Bank, M&T Bank,
? S? 1?'r?{lGI+iED SVI£ET E"0? Ppf?ESSfS
'I'F-c., Garnishees;
(5) Amount due $ 445,615.25
Total $ 445.615.25
CERTIFICATION
I certify that:
(a) this Praecipe is based upon a judgment entered by confession, and
(b) Notice will be served with the Writ of Execution pursuant to Rule 2958.3.
-2-
Attorney for Plaintiff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N004-4783 Civil
TO THE SHERIFF OF CIVIL ACTION - LAW
To sariCUMBERLAND COUNTY:
sly the debt, interest and costs due THE LEGACY BANK Plaintiff(s)
From HEALTHCORE, LLC, 47 W, POMFRET ST., CARLISLE PA 17013.
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of CITIZENSS BANK, 665 N EAST ST, CARLISLE PA 17013: COMMUNITY BANKS, 1178
NEWVH,LEi RD, CARLISLE PA 17013 AND M&T BANK, I W HIGH ST, CARLISLE PA
17013 GARNISHEE(S) as follows:
ATTACH THE PROPERTY OF DEFT IN POSSESSION OF GARNISHEE BANKS INCLUDING
BUT NOT LIMITED TO ANY FUNDS ON ACCOUNT AND BANK DEPOSITS. KINDLY SERVE
INTERROGATORIES UPON GARNISHEE BANKS.
and to notify the garnishee(s) that: (a) 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
(s) or otherwise disposing thereof
any Property
defendant
(3) If property 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $445,615.25
Interest L.L. $.50
Arty's Comm %
Arty Paid $37.50
Plaintiff Paid
Date: SEPTEMBER 30, 2004
(Seal)
REQUESTING PARTY:
Name F. STEPHENSON MATTHES, ESQ.
Address: P O BOX 889,111 N FRONT ST
HARRISBURG PA 17110
Attorney for: PLAINTIFF
Telephone: (717) 234-4121
Supreme Court ID No. 67408
Due Frothy $1.00
Other Costs
CURTIS R. LONG
Prothorufty
By:
? Deputy
IN THE COURT OF COMMONS PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THE LEGACY BANK,
2600 Commerce Drive
Harrisburg, PA 17110,
CIVIL DIVISION
Plaintiff
vs.
HEALTHCORE, LLC,
47 West Pomfret Street,
Carlisle, PA 17013,
Defendant,
and
M&T BANK,
Garnishee.
NO. 04-4783
ly,q'9 11f
OP P Iq
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N,q,?,?®,yrs
INTERROGATORIES TO GARNISHEE
TO: M&T BANK
1 West High Street
Carlisle, PA 17013
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.
1. At the time you were served or at any subsequent time did you owe the
Defendants any money or were you liable to him on any lease, mortgage or on any negotiable or
other written instrument, or did they claim that you owed them any money or were liable to them
for any reason.
ANSWER:
2. ' If the answer to Interrogatory 1 is in the affirmative, state the following: (a) the
amount of money you owe or owed to Defendants; (b) if such money is in the form of a fund, the
present location thereof; (c) the amount or amounts that Defendants claim or claimed that you
owe or o%ved to him; (d) the nature and amount of each of such liabilities.
ANSWER:
3. At the time you were served or at any subsequent time was there in your
possession, custody or control of yourself and one or more other persons any property of any
nature owned solely or in part by the Defendants.
ANSWER:
tips
NO A? T9
O
T
4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market
value and present location of each of such properties.
ANSWER:
5. At the time you were served or at any subsequent time did you hold legal title to
any property of any nature owned solely or part by the Defendants or in which Defendants held or
claimed any interest?
ANSWER:
-2-
6. ' If the answer to Interrogatory 5 is in the affirmative, described the nature, fair
market value and present location of each of said properties.
ANSWER:
7. At the time you were served or at any subsequent time did you hold as fiduciary
any property in which the Defendants had an interest?
ANSWER:
tiq
ENO AV T9
.cFN N?
C
COUNTS
6. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market
value and present location of each of such properties.
ANSWER:
9. At any time before or after you were served, did the Defendants transfer or deliver
any property to you or to any person or place pursuant to your directions or consent, and if so
what was the consideration thereof?
ANSWER:
-3-
. 10. ' If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market
value and present location of each of such properties.
ANSWER:
11. At any time after you were served did you pay, transfer or deliver any money or
property to the Defendants or to any person or place pursuant to his direction or otherwise
discharge any claim of the Defendants against you?
ANSWER:
JANICE M. GLASGOW
M&T BANK
101's Q4
P.C.
D.
BANK FIN:233042-1 016986-120545
Matthes,
111 North Front Street
P.O. Box 889
Harrisburg, PA 17110
p. 717.234.4121
-4-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL DIVISION
THE LEGACY BANK
Plaintiff(s),
vs.
HEALTHCORE, LLC
Defendant(s),
vs.
CITIZENS BANK OF PA,
Garnishee.
No. 04-4783
Praecipe for Appearance
Code: 200 Execution
Filed on Behalf of Garnishee,
Citizens Bank of PA
Counsel of Record for
this Party:
David F. Mowrey, Esquire
PA I.D. No. 30431
2 Commerce Square
2001 Market Street
Suite 600
Philadelphia, PA 19103
(267)-671-1033
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL DIVISION
PRAECIPE
TO: Office of the Prothonotary
One Courthouse Square
Courthouse
Carlisle, PA 17013-3387
Sir:
Kindly enter my appearance on behalf of Garnishee, Citizens Bank of PA
? h
David F. Mowrey, Esquire 0
2 Commerce Square
2001 Market Street
Suite 600
Philadelphia, PA 19103
Certificate of Service
I, David F. Mowrey, hereby certify that a true and correct copy of this Praecipe for
Appearance has been served upon the following by depositing it in the U. S. Mail, postage
prepaid, this jq TM day of 2004.
F. STEPHENSON MATTHES,
ESQUIRE
111 NORTH FRONT STREET
P.O. BOX 889
HARRISBURG PA 17110
HEALTHCORE,LLC
David F. Mowrey squire
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2004-04783 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
LEGACY BANK THE
VS
HEALTHCORE LLC
And now RICHARD SMITH
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0012:00 Hours, on the 8th day of October , 2004, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
HEALTHCORE LLC , in the
hands, possession, or control of the within named Garnishee
M & T BANK 1 WEST HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
KIM SEAVERS (TELLER) ,
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to Her .
Sheriff's Costs: So 00ir
Docketing .00 rte' / No J%IW- ?
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
.00
00/00/0000
Sworn and subscribed to before me
this )9 1?? day of CCU,
p?(w)q, A-D. Q-tdhonotar j
By
puty Sheriff
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2004-04783 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
LEGACY BANK THE
VS
HEALTHCORE LLC
And now BRIAN BARRICK Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:35 Hours, on the 13th day of October , 2004, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
HEALTHCORE LLC
hands, possession, or control of the within named Garnishee
COMMUNITY BANKS 201 ST JOHNS CHURCH ROAD
CAMP HILL, PA 17011
Cumberland County, Pennsylvania, by handing to
PAULETTE ROVITO (MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to Her .
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
00
, in the
true
and made
So answe
- -Klan ?
R. Thomas Kline
Sheriff of Cumberland County
00/00/0000
Sworn and subscribed to before me
this Z k rf day of By
,W 'T A.D.
Pro?tary !-7
IQO? 4i__
Deputy Sheriff
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2004-04783 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
LEGACY BANK THE
VS
HEALTHCORE LLC
And now JASON VIORAL
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:54 Hours, on the 7th day of October , 2004, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
HEALTHCORE LLC , in the
hands, possession, or control of the within named Garnishee
CITIZENS BANK 665 NORTH EAST ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
CATHY COLE (ASST. MANAGER) ,
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to Her .
Sheriff's Costs: So answers:
Docketing .00??iA
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
00
00/00/0000
Sworn and subscribed to before me
By
this day of Off, uty Sheriff
A.D.
9YLe-VX?a.. v
Prot o otary
The Legacy Bank
VS
Healthcore of Maryland, LLC
Writ of Execution
Docket No. 2004-4783 Civil Term
OF T
2009 AUG 31 Aid 11 * 14
CUM" NTY
And Now, August 25, 2009, R. Thomas Kline, Sheriff, who being duly sworn
according to law, states the above captioned writ is returned ABANDONDED. No action
has been taken since October 18, 2004.
Sheriff s Costs:
Docketing
Surcharge
Garnishee
Levy
Mileage
Prothonotary
Poundage
So Answers:
$18.00
70.00
27.00
60.00
11.10
1.50
3.75 ?
$191.35
R. Thomas Kline, Sheriff
BY tW _
Sergeant
s `j"00 Co
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('70- 'n-30d '-
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