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HomeMy WebLinkAbout12-1866KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 FULTON BANK, N.A. Plaintiff V. THE DINGELDEIN BAKERY, INC Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Id- /8!& CIvi/T m CONFESSION OF JUDGMENT CONFESSION OF JUDGMENT By virtue of the authority conferred by the Note, a copy of which is attached to the Complaint filed in this action, I appear for the Defendant and confess judgment in favor of the Plaintiff and against the Defendant for the sum of $236,932.51 and costs of suit. C/ Eugene E. Pepinsky, Jr. Attorney for Defendant by virtue of the authorization contained in the Note c-z .kn. r R? ,:; is -$46.00 P6 MTY err qoo a9,A NA ee KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 FULTON BANK, N.A. Plaintiff V. THE DINGELDEIN BAKERY, INC. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LL NO. CONFESSION OF JUDGMENT NOTICE OF DEFENDANT'S RIGHTS A judgment in the amount of $236,932.51 has been entered against you and in favor of the Plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper allegedly signed by you. The sheriff may take your money or other property to pay the judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the judgment or to prevent your money or property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER AND CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. PENNSYLVANIA LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 s. Bedford Street Carlisle, PA 17013 (717) 249-3166 KEEFER WOOD ALLEN & RAHAL, LLP By: Eugene E. a 'ns y, . Attorney I.D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Fulton Bank, N.A. KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 FULTON BANK, N.A. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THE DINGELDEIN BAKERY, INC. NO. a _ ?g6G G ??"` Defendant CONFESSION OF JUDGMENT COMPLAINT 1. Plaintiff Fulton Bank, N.A. is a national banking association, with an office at 200 N. Third Street, Harrisburg, Pennsylvania 17101. 2. Defendant is The Dingeldein Bakery, Inc., a Pennsylvania corporation, whose last known address is 316 Bridge Street, New Cumberland, Pennsylvania 17070. 3. On or about September 19, 2006, Defendant, for good and valuable consideration, executed and delivered a Promissory Note (the "Note") to Plaintiff. A true and correct copy of the Note is attached hereto, made a part hereof and marked Exhibit "A". 4. The Note referred to in Paragraph 3 above has not been assigned by Plaintiff to any person or organization. 5. Judgment has not been entered on the Note referred to in Paragraph 3 above in any jurisdiction. 6. The Note provides that Plaintiff may confess judgment against Defendant at any time after a default for the unpaid principal balance of the Note plus accrued interest and late charge together with costs of suit and attorneys' fees of the greater of ten percent (10%) or $500.00. 7. The obligations of Defendant are in default, among other things, by reason of its failure to make the required payment(s) due under the Note. KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 8. The amount due on the Note as of March 21, 2012, is $215,393.51, of which $211,716.48 is principal and $2,241.54 is interest and $1,435.49 is late charges. 9. Plaintiff has been advised and, therefore, avers that Defendant executed the Note referred to in Paragraph 3 above for business purposes. 10. This confession of judgment is not being filed against a natural person(s) in regards to consumer credit transaction. WHEREFORE, Plaintiff demands judgment against Defendant in the sum of $236,932.51 together with interest as may hereafter accrue and costs of suit. KEEFER WOOD ALLEN & RAHAL, LLP Date: March ?-I, 2012 BY Eugene . Pepinsky, Jr. Attorney I.D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 VERIFICATION The undersigned, James W. Pesavento, hereby verifies and states that: He is Vice President of Fulton Bank, N.A., Plaintiff herein; 2. He is authorized to make this Verification on its behalf; 3. The facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief; and 4. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. 1 4904, relating to unsworn falsification to authorities. W. Pesavento Dated: MarchZ Z , 2012 ?IIIN N?NNNIIIINIII?I?N?IIINIIIN ?IIIIIININIII?IIII?IIIINNIINI?IINIII ?? UL IN INIIIINIIIN??IININNINII?NNINNNNINI DPROMISSORY NOTE Borrower: The Dingeldein Bakery, Inc. Lender: Fulton Bank 316 Bridge Street Now Cumberland Office New Cumberland, PA 17070 Corporate Address One Penn Square Lancaster, PA 17602 Principal Amount; $240,000.00 Data of Note: September 19, 2006 PROMISE TO PAY. The Dingeldein Bakery, Inc, 1"Borrower") promises to pay to Fulton Bank ("Lender"), or order, In lawful money of the United States of America, the principal amount of Two Hundred Forty Thousand & 00/100 Dollars ($240,000,00), together with interest on the unpaid principal balance from September 19, 2006, until paid In full. PAYMENT. Subject to any payment changes resulting hom changes in the Index, Borrower will pay this loan in accordance with the following payment schedule: 239 consecutive monthly installments on account of principal and Interest in the amount of $1,994.45 each, beginning on October 19, 2006 and continuing on the 19th day of each month thereafter, One final payment of all unpaid principal and all unpaid accrued Interest shall be due and payable on September 19,2026. INTEREST RATE. The interest rate applicable hereunder is the annual fixed rate of 7.80% tot a period of 60 months from the date hereof, followed by the annual variable rate of the Index, as hereinafter defined. Unless otherwise agreed or required by applicable law, payments will be applied first to any accrued unpaid interest; then to principal; then to any late charges; and then to any unpaid collection costs. The annual interest rate for this Note Is computed on a 3651360 basis; that is, by applying the ratio of the annual interest rate over a year of 360 days, multiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance is outstanding. Borrower will pay Lander at Lender's address shown above or at such other place as Lender may designate In writing. VARIABLE INTEREST RATE. The interest rate on this Note Is subject to change from time to time based on changes in an index which is the Fulton Bank Prime Rate fthe "Index"). The Index is not necessarily the lowest rate charged by Lender on its loans and Is sot by Lender in its sole discretion, If the Index becomes unavailable during the term of this loan, Lender may designate a substitute index after notifying Borrower. Lender will tell Borrower the current Index rate upon Borrower's request. The interest rate change will not occur more often than each day. Borrower understands that Lender may make loans based on other rates as wall. The interest rate to be applied to the unpaid principal balance during this Note will be at a rate equal to the Index. NOTICE: Under no circumstances will the interest rate on this Note be more than the maximum rate allowed by applicable law. Whenever Incresses.occur in the interest rate, Lender, at Its option, may do one or more of the following: (A) increase Borrower's payments to ensure Borrower's loan will pay off by its original final maturity date, IB) Increase Borrower's payments to cover accruing interest, (C) increase the number of Borrower's payments, and ID) continue Borrower's payments at the same amount and increase Borrower's final payment. PREPAYMENT PENALTY. Upon prepayment of this Note, Lender is entitled to the following prepayment penalty: The Borrower shall have the right to prepay the whole or any part of the principal and interest hereunder provided that: la) at the time of prepayment no event of default hereunder shall have occurred; Ibl any prepayment during any fixed rate period shall be accompanied by a prepayment penalty equal to two 12%) percent of the amount; Ic) any partial prepayment shall be applied to the unpaid principal balance, and no prepayment shall reduce the amount of the scheduled installments nor relieve the Borrower from paying the scheduled installments on each due date, until the entire indebtedness is paid. Notwithstanding anything to the contrary set forth above, the prepayment penalty will not be charged If up to twenty (20%) percent of the original principal amount is prepaid from internally generated funds within any loan year. The term "loan year' as used herein is defined as any period of one year commencing on the date hereof or on any anniversary of such date. Except for the foregoing, Borrower may pay all or a portion of the amount owed earlier than It Is due. Early payments will not, unless agreed to by Lender in writing, relieve Borrower of Borrower's obligation to continue to make payments under the payment schedule. Rather, early payments will reduce the principal balance due and may result in Borrower's making fewer payments. Borrower agrees not to send Lender payments marked "paid in full", "without recourse", or similar language. It Borrower sends such a payment, Lender may accept it without losing any of Lender's rights under this Note, and Borrower will remain obligated to pay any further amount owed to Lender. All written communications concerning disputed amounts, including any check or other payment instrument that indicates that the payment constitutes "payment in full" of the amount owed or that is tendered with other conditions or limitations or as full satisfaction of a disputed amount must be mailed or delivered to; Fulton Bank, New Cumberland Office, Corporate Address, One Penn Square, Lancaster, PA 17602. LATE CHARGE. II a payment ib 16 days or more late, Borrower will be charged 5.000% of the unpaid portion of the regularly scheduled payment. INTEREST AFTER DEFAULT. Upon default, including failure to pay upon final maturity, the interest rate on this Note shall be increased by adding a 5.000 percentage point margin I"Default Rate Margin"). The Default Rate Margin shall also apply to each succeeding interest rate change that would have applied had there been no default. If judgment is entered In connection with this Note, interest will continue to accrue after the date of judgment at the rate in effect at the time judgment is entered. However, in no event will the interest rate exceed the maximum interest rate limitations under applicable law. DEFAULT, Each of the following shall constitute an event of default ("Event of Default") under this Note: Payment Default. Borrower Jails to make any payment when due under this Note. Other Defaults. Borrower Jails to comply with or to perform any other term, obligation, covenant or condition contained In this Note or in any of the related documents or to comply with or to perform any term, obligation, covenant or condition contained in any other agreement betwoon Lender and Borrower. Default in Favor of Third Parties. Borrower or any Grantor defaults under any loan, extension of credit, security agreement, purchase or sales agreement, or any other agreement, in favor of any other creditor or person that may materially effect any of Borrower's property or Borrower's ability to repay this Note or pyriorm Borrower's obligations under this Note or any of the related documents. False Statements. Any warranty, rapresentation or statement made or furnished to Lender by Borrower or on Borrower's behalf under this Note or the related documents is false or misleading in any material respect, either now or at the time made or furnished or becomes false or misleading at any time thereafter, insolvency. The dissolution or termination of Borrower's existence as a going business, the Insolvency of Borrower, the appointment of a receiver for any part of Borrower's property, any assignment for the benefit of creditors, any type of creditor workout, or the commencement of any proceeding under any bankruptcy or insolvency laws by or against Borrower. Creditor or Forfeiture Proceedings. Commencement of foreclosure or forfeiture proceedings, whether by judicial Proceeding, self-help, repossession or any other method, by any creditor of Borrower or by any governmental agency against any collateral securing the loan. This includes a garnishment of any of Borrower's accounts, Including deposit accounts, with Lender. However, this Event of Default shall not apply it there is a good faith dispute by Borrower as to the validity or reasonableness of the claim which is the basis of the creditor or forfeiture proceeding and if Borrower gives Lender written notice of the creditor or forfeiture proceeding and deposits with Lender monies or a surety bond for the creditor or forfeiture proceeding, in an amount determined by Lender, in its sole discretion, as being an adequate reserve or bond for the dispute. Events Affecting Guarantor. Any of the preceding events occurs with respect to any Guarantor of any of the Indebtedness or any Guarantor dies or becomes incompotent, or revokes or disputes the validity of, or liability under, any guaranty of the indebtedness evidenced by this Note. In the event of a death, Lender, at Its option, may, but shall not be required to, permit the Guarantor's estate to assume unconditionally the obligations prising under the guaranty in a manner satisfactory to Lender, and, in doing so, cure any Event of Default. Change in Ownership. Any chsnge in ownership of twenty-five percent (26%) or more of the common stock of Borrower. Adverse Change. A material adverse change occurs in Borrower's financial condition, or Lender believes the prospect of payment or performance of this Note Is impaired. Insecurity. Lender in good faith believes itself Insecure. 2 Loan No: 0001-9708275-9001 PROMI1SORY NOTE IC tinued) Page 2 Cure Provisions. If any default, other than a default in payment Is* curable and it Borrower has not boon given a notice of a breach of the same provision of this Note within the preceding twelve 112) months, it may be cured if Borrower, after receiving written notice from . Lender demanding cure of such default: (1) cures the default within fifteen 05) days; or (2) If the cure requires more then fifteen (15) - days, Immediately initiates steps which Lender deems in Lender's sole discretion to be sufficient to cure the default and thereafter continues and completes all reasonable and necessary steps sufficient to produce compliance as soon as reasonably practical. LENDER'S RIGHTS, Upon default, Lender may, after giving such notices as required by applicable law, declare the entire unpaid principal balance under this Note and all accruod unpaid interest immediately due, and then Borrower will pay that amount. ATTORNEYS' FEES; EXPENSES. Lender may hire or pay someone also to help collect this Note If Borrower does not pay. Borrower will pay Lender that amount. This includes, subject to any limits under applicable law, Lender's attorneys' fees and Lender's legal expenses, whether or not there Is a lawsuit, including attorneys' loos, expenses for bankruptcy proceedings lincluding efforts to modify or vacate any automatic stay or injunction), and appeals. If not prohibited by applicable low, Borrower also will pay any court costs, in addition to all other sums provided by law. JURY WAIVER. Lender and Borrower hereby waive the right to any jury trial in any action, proceeding, or counterclaim brought by either Lender or Borrower against the other. GOVERNING LAW. This Note will be governed by federal low applicable to Lender and, to the extent not preempted by federal law, the laws of the Commonwealth of Pennsylvania without regard to its conflicts of law provisions. This Note teas been accepted by Lender in the Commonwealth of Pennsylvania. RIGHT OF SETOFF, To the oxtent permitted by applicable law, Lander reserves a right of setoff In all Borrower's accounts with Lender (whether chocking, savings, or some other account). This Includes all accounts Borrower holds jointly with someone else and all accounts Borrower may open in the future. However, this does not include any IRA or Keogh accounts, or any trust accounts for which setoff would be prohibited by law. Borrower authorizes Lender, to the extent permitted by applicable law, to charge or setoff all sums owing on the indebtedness against any and all such accounts, and, at Lender's option, to administratively freeze all such accounts to allow Lender to protect Lender's charge and setoff rights provided in this paragraph. COLLATERAL, Borrower acknowledges this Note Is secured by Mortgage on 314-316 Bridge Street, Borough of Now Cumberland, Cumberland County, PA; CROSS DEFAULT. Any event of default under any loan duo and owing to Lender by Borrower, at any time, shell constitute an event of default under all loans due and owing to Lender by Borrower. SUCCESSOR INTERESTS. The terms of this Note shall be binding upon Borrower, and upon Borrower's heirs, personal representatives, successors and assigns, and shall inure to the benefit of Lender and its successors and assigns. GENERAL PROVISIONS. If any part of this Note cannot be enforced, this fact will not affect the rest of the Note. Lender may delay or forgo enforcing any of its rights or remedies under this Note without losing them. Borrower and any other person who signs, guarantees or endorses this Note, to the extent allowed by low, waive presentment, demand for payment, and notice of dishonor. Upon any change in the terms of this Note, and unless otherwise expressly stated in writing, no party who signs this Note, whether as maker, guarantor, accommodation maker or endorser, shall be released from liability. All such parties agree that Lender may renew or extend irepeatedly and for any length of time) this loan or release any party or guarantor or collateral; or impair, fail to realize upon or perfect Lender's security Interest in the collateral; and take any other action deemed necessary by Lender without the consent of or notice to anyone. All such parties also agree that Lender may modify this loan without the consent of or notice to anyone other then the party with whom the modification is made. The obligations under this Note are joint and several. If any portion of this Note is for any reason determined to be unenforceable, It will not affect the enforceability of any other provisions of this Note. CONFESSION OF JUDGMENT. BORROWER HEREBY IRREVOCABLY AUTHORIZES AND EMPOWERS ANY ATTORNEY OR THE PROTHONOTARY OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY TIME FOR BORROWER AFTER A DEFAULT UNDER THIS NOTE AND WITH OR WITHOUT COMPLAINT FILED, CONFESS OR ENTER JUDGMENT AGAINST BORROWER FOR THE ENTIRE PRINCIPAL BALANCE OF THIS NOTE AND ALL ACCRUED INTEREST, LATE CHARGES AND ANY AND ALL AMOUNTS EXPENDED OR ADVANCED BY LENDER RELATING TO ANY COLLATERAL SECURING THIS NOTE, TOGETHER WITH COSTS OF SUIT, AND AN ATTORNEY'S COMMISSION OF TEN PERCENT (10%) OF THE UNPAID PRINCIPAL BALANCE AND ACCRUED INTEREST FOR COLLECTION, BUT IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS 0500) ON WHICH JUDGMENT OR JUDGMENTS ONE OR MORE EXECUTIONS MAY ISSUE IMMEDIATELY; AND FOR SO DOING, THIS NOTE OR A COPY OF THIS NOTE VERIFIED BY AFFIDAVIT SHALL BE SUFFICIENT WARRANT. THE AUTHORITY GRANTED IN THIS NOTE TO CONFESS JUDGMENT AGAINST BORROWER SHALL NOT BE EXHAUSTED BY ANY EXERCISE OF THAT AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND AT ALL TIMES UNTIL PAYMENT IN FULL OF ALL AMOUNTS DUE UNDER THIS NOTE. BORROWER HEREBY WAIVES ANY RIGHT BORROWER MAY HAVE TO NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF JUDGMENT AND STATES THAT EITHER A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THIS CONFESSION OF JUDGMENT PROVISION TO BORROWER'S ATTENTION OR BORROWER HAS BEEN REPRESENTED BY INDEPENDENT LEGAL COUNSEL. PRIOR TO SIGNING THIS NOTE, BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE, INCLUDING THE VARIABLE INTEREST RATE PROVISIONS. BORROWER AGREES TO THE TERMS OF THE NOTE. BORROWER ACKNOWLEDGES RECEIPT OF A COMPLETED COPY OF THIS PROMISSORY NOTE. THIS NOTE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS NOTE IS AND SHALL CONSTITUTE AND HAVE THE EFFECT OF A SEALED INSTRUMENT ACCORDING TO LAW. BORROWER: TH DIN DEIN BAKE INC. 1?1 C g ? (Sea I) a 'e J. i eldeln, ecretary/Treasurer of The Dingoldein kery, Inc. - rr Guaranties of Russell K. Dengeldein and Laurie J, Dingeldsin. Witness 4---Q4-AU Seal ) i` n FULTON BANK `Lender' O Supplement to Promissory Note 3) 1 /oy yr I Page I of I Date: The provisions set forth in this Supplement constitute additional provisions or modifications of that certain Promissory Note dated September 19, 2006 in the original principal amount of $240,000,00, and as amended (the "Note") executed by the Undersigned (the "Borrower") in favor of Lender indicated above. N; 1. The provisions of this Supplement shall be deemed to be fully incorporated by reference in and shall constitute provisions of the Note as of the dale of this Supplement. t • 2. Except as expressly supplemented or modified by this Supplement, the Note shall continue in full force and effect in accordance with its terms, conditions, covenants and provisions, all of which are hereby reaffirmed in their entirety except as supplemented or modified hereby. 3. Terms not defined to this Supplement shall have the meanings ascribed to them in the Note. ,j 4. Borrower hereby covenants and agrees as follows: Effective March 19, 2009 the interest rate is the fixed rate of 7.50°/ per annum for five (5) years, and thereafter the interest rate will be the variable rate of two percent (2.00%) over the Lender's prime rate of interest to effect from time to time. The Note shall be payable in 239 consecutive monthly installments on account ol` principal and interest in the amount of $1,838.57 each, beginning April 30, 2009 and continuing on the 30" day of each month thereafter. One final payment of all unpaid principal and all unpaid accrued interest shall be due and payable on March 30, 2029; provided, however, Lender shall have the option at each five (5) year anntversary•from the date hereof, to declare the entire then outstanding principal balance and all accrued unpaid interest to be due and payable thiny (30) days following written notice to the Borrower that Lender is exercising such T, Qpiion.` The Undersigned shall have the right to prepay the whole or any pan of the principal and interest hereunder provided that: (a) at the time of prepayment no event of default hereunder shall have occurred, (b) any prepayment during any fixed rate period shall be accompanied by a 'I,, prepayment penalty equal to two percent (2%) of the amount, (c) any partial prepayment shall be applied to the unpaid principal balance, and no prepayment shall reduce the amount of the scheduled installments nor relieve the Undersigned from paying the scheduled installments on each due date until the entire indebtedness is paid. Notwithstanding anything to the contrary set forth above, the prepayment penalty will not be charged if up to twenty percent (20%) of the original principal amount is prepaid from internally generated funds within any loan year. The term 'loan year', as used herein, is defined as any period of one year commencing on March 19, 2009 or on any anniversary of such date. The paragraph titled VARIABLE INTEREST RATE shall be amended with the addition of the following language: NOTICE: Under no circumstances will the interest rate on this Note be less than 6.000% per annum or more than the maximum rate allowed by applicable law. 1 Witness the due execution of this Supplement to Promissory Note, The Dingeldem Bakery, Inc. under Seal and INTENDING TO 131? LEGALLY BOUND t. HEREBY, on the day and year first above wrinen. } By: c Russel ein, Presi nt of The Dmgeldein Bakery, Inc. By: Laurie o Ding em, Treasurer of The Dingeldem Bakery, Inc. t :1a 1. c Account Number 0001-9708275-9001 A KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 FULTON BANK, N.A. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. THE DINGELDEIN BAKERY, INC. Defendant CIVIL ACTION - LAW NO. /a - 18&(p Oivii Tim CONFESSION OF JUDGMENT NOTICE To: THE DINGELDEIN BAKERY, INC., Defendant You are hereby notified that on March . , 2012, judgment by confession was entered against you in the sum of $236,932.51 in the above caption cas P otary qmw YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. PENNSYLVANIA LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 s. Bedford Street Carlisle, PA 17013 (717) 249-3166 I hereby, certify that the following is the address of the Defendants stated in the certificate of residence. THE DINGELDEIN BAKERY, INC. 316 BRIDGE STREET NEW CUMBERLAND PA 17070 ( iffs) Attorney forPta ?5?, ?.. set:: 2- ? .... ,: ?'" KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 FULTON BANK, N.A. Plaintiff V. THE DINGELDEIN BAKERY, INC Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NOTICE To: THE DINGELDEIN BAKERY, INC., Defendido CIVIL ACTION - LAW NO. CONFESSION OF JUDGMENT Usted esta siendo notificando que el de March del 2012, se anoto en contra suya un fallo por confesion en la suma de $236,932.51 en el caso mencionado en el epigrafe. Prothonotary LISTED DEBE LLEVAR IMMEDIATAMENTE ESTE DOCUMENTO A SU ABOGADO. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A LINO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. PENNSYLVANIA LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 s. Bedford Street Carlisle, PA 17013 (717) 249-3166 Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: THE DINGELDEIN BAKERY, INC. 316 BRIDGE STREET NEW CUMBERLAND PA 17070 Attorney