HomeMy WebLinkAbout12-4015IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
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ORRSTOWN BANK NO. 19- LI CA 5 -z
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LIGHTSTYLES, LTD. C
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ENTRY OF APPEARANCE CONFESSION °'
OF JUDGMENT
Pursuant to the authority contained in the Promissory Note dated March 2, 2011, a copy
of which is attached to the Complaint in Confession of Judgment filed in this action, I appear for
the Defendant and confess judgment in favor of Plaintiff, Orrstown Bank, and against Defendant,
Lightstyles, Ltd.
Principal: $1,462,313.74
Interest as of March 26, 2012: 6,345.11
Loan Admin Fee 200.00
Legal Fees 2,000.00
Total $1,470,858.85
Dilworth Paxson LLP
By: LL&
Elizabeth J. Goldstein, Esquire
Attorney for Defendant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW ? 4-;
ORRSTOWN BANK NO.
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COMPLAINT IN CONFESSION OF JUDGMENT o -.?
Plaintiff files this Complaint pursuant to Pennsylvania Rule of Civil Procedure 2951(b)
for judgment by confession and avers the following:
1. Plaintiff is Orrstown Bank, a bank authorized to do business under the laws of the
Commonwealth of Pennsylvania with an office at 77 East King Street, Shippensburg,
Pennsylvania 17257.
2. Defendant is Lightstyles, Ltd., a Pennsylvania Corporation with an address 1216
Claremont Road, Carlisle, Cumberland County, Pennsylvania 17015.
3. Defendant, Lightstyles, Ltd., for good and valuable consideration, made and
executed in favor of Plaintiff, Orrstown Bank, a Promissory Note dated March 2, 2011 in the
principal amount of $1,500,000. A true and correct copy of said Promissory Note is attached
hereto as Exhibit "A" and made a part hereof.
4. Defendant, Lightstyles, Ltd., owes Plaintiff, Orrstown Bank, the following under
the terms of said Promissory Note:
Principal: $1,462,313.74
Interest as of March 26, 2012: 6,345.11
Loan Admin Fee 200.00
Legal Fees 2,000.00
Total $1,470,858.85
93968552
5. Said Promissory Note is in default for Defendant's failure to pay principal and
interest when due and owing and the existence of an unsatisfied judgment against defendant for
more than 20 days which judgment remains unsatisfied to date. Notice of default was provided
on April 5, 2012 and Defendant Lightstyles did not cure within the applicable cure period.
6. Judgment has not previously been entered on said Promissory Note in any
jurisdiction.
7. There have been no assignments of said Promissory Note.
8. Judgment is not being entered by confession against a natural person in
connection with a consumer credit transaction.
WHEREFORE, Plaintiff, Orrstown Bank, demands judgment against Defendant,
Lightstyles, Ltd, in the amount of $1,470,858.85.
Dilworth Paxson, LLP
By: VZ1 ? e-14 /,
Eliz eth Goldstein, Esquire
Martin J. Weis, Esquire
Dilworth Paxson LLP
112 Market St., Suite 800
Harrisburg, PA 17101
(717) 236-4812
93968552
Exhibit "A"
Carlisle, Pennsylvania
March 2, 2011
$1,500,000;00
MORTGAGE NOTE
FOR VALUE RECEIVED, the undersigned LIGHTSTYLES, LTD. (the "Maker"),
promises to pay to the order of ORRSTOWN BAND. (the "Lender"), at its offices located at 2965
Philadelphia Avenue, Chambersburg, Pennsylvania 17201, or at such other places as the Lender
may from time to time designate, the principal sum of ONE MILLION FIVE HUNDRED
THOUSAND DOLLARS ($1,500,000.00), lawful money of the United States of America, together
with interest thereon payable at the rate or rates hereinafter specified and any and all other sums
which may be owing to the Lender by the Maker pursuant to this Note. The following terms shall
apply to this Note:
1. Interest Rate. Commencing on the date of this Note and continuing for a period of
five (5) years, interest shall accrue on the unpaid principal balance outstanding from time to time at
a fixed per annum rate of interest equal to Six and 501100 percent (6.50%). At the end of such
initial fixed rate period, the Lender may, in its sole discretion, quote new fixed rates. If the Lender
chooses not to offer another fixed rate, or Maker does not accept any of the quoted fixed rates, then
upon the expiration of the initial five (5) year fixed rate period and continuing thereafter until all
sums due under this Note, whether principal, interest, charges, fees or other sums are paid in full,
interest shall accrue on the unpaid principal balance outstanding from time to time at a per annum
variable rate of interest equal to the greater of (i) the Wall Street Journal Prime lus One percent
(1.00%), or (ii) Five percent (5.00%). When a variable rate of interest is to apply, the rate of
interest under this Note shall change automatically, without notice, as and when there has been a
change in the Wall Street Journal Prime. The Maker acknowledges that to the extent interest is to
accrue on the outstanding principal balance at a rate based upon the Wall Street Journal Prime, such
rate is only one of the bases used for accruing interest on loans made by the Lender and that by
basing the rate of interest under this Note on the Wall Street Journal Prime, the Lender has not
committed to charge, and the Maker has not in any way bargained for, interest based on a lower rate
or the lowest rate at which the Lender may now, or in the future, make loans to other borrowers.
The Lender's determination of the Wall Street Journal Prime shall be conclusive absent manifest
error.
2. Calculation of Interest. Interest accruing for any period shall be calculated by
multiplying the unpaid principal balance of this Note by the applicable rate of interest and by
multiplying the product thereof by a factor equal to the number of days in such period divided by
three hundred sixty (360).
3. Repayment. Commencing on April 2, 2011 and continuing on the same day of each
month thereafter, Maker shall make two hundred thirty-nine (239) consecutive monthly payments of
principal and interest in the amount of Eleven Thousand Two Hundred Sixty-seven and 42/100
Dollars ($11,267.42) each, and one final payment in the amount of the entire unpaid balance of
principal and all accrued and unpaid interest and all other sums due and owing under this Note, on
March 2, 2031, which shall' be the final and absolute due date of this Note (the `'Maturity Date");
8U?3aa.3
provided, however, that if there is a change in the interest rate, the amount of the monthly
installment payments of principal and interest may be adjusted from time to time as determined to
be necessary by Lender in order to assure the repayment of the amounts due hereunder in
substantially equal installment payments of principal and interest based upon an agreed upon two
hundred forty (240) month amortization.
4. Late Payment Charge. If any payment due hereunder is received by the Holder
more than fifteen (15) calendar days after its due date, the Maker shall pay a late payment charge of
five percent (5%) of the amount overdue.
5. Application of Payments. All payments made hereunder shall be applied first to late
payment charges or other sums owed to the Holder, next to accrued interest, and then to principal,
or in such other order or proportion as the Holder, in the Holder's sole and absolute discretion, may
elect from time to time.
6. Prepayment. If the Maker prepays the principal amount outstanding under this Note,
in whole or in part, at any time during a fixed interest rate period, then a prepayment premium equal
to five percent (5%) of the principal amount prepaid shall be paid by Maker to the Holder together
with such prepayment; provided that the prepayment premium ercentage shall be reduced by one
percent point (1.00%) at each of the 'first (Is) through fifth (5' ) anniversaries of first (1") day of
such fixed interest rate period; and provided further that no prepayment premium will be charged on
any amount prepaid from internally generated (not borrowed) funds. Subject to Section 5 of this
Note, any partial prepayment shall be applied to principal in reverse order of maturity and shall not
betaken or construed as a substitution for regularly scheduled payments.
7. Collateral. This Note is secured by that certain Mortgage and Security Agreement of
even date herewith, made by Robert. L. Slagle and Susan DeRemer Slagle, as Mortgagors, for the
benefit of the Lender, encumbering certain real property known as 39691 Hampton Lane, North
Bethany, Sussex County, Delaware, the provisions of which are incorporated into this Note by
reference.
8. Default and Default Interest Rate. In the event of any failure of the Maker to pay
any amount due under this Note when the same becomes due and payable, or an Event of Default
occurs under any of the Documents, subject to the giving of such notice and the expiration of such
cure period, if any, as may be required therein (each an "Event; of Default"), and for so long as the
Event of Default is continuing, the Holder, in the Holder's sole discretion and without notice or
demand, may raise the rate of interest accruing on the unpaid principal balance to a rate per annum
equal to the rate of interest otherwise applicable pursuant to Section 1 of this Note laws five percent
(50/o), but not more than the maximum rate allowed by law (the "Default Rate or "Penalty Rate"),
independent of whether the Holder elects to accelerate the unpaid principal balance as a result of
such Event of Default. Such interest shall continue to accrue despite any legal moratorium on
payment or any delay in payment ordered or permitted by any court assuming jurisdiction.
9. Acceleration. Upon an Event of Default, the principal amount outstanding on this
Note. together with interest, charges, fees or other sums shall, at the option of the Holder, or as
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otherwise provided in the Agreement, without notice or demand, become inunediately due and
payable.
10. Confession of Judgment. UPON AN EVENT OF DEFAULT (SUBJECT TO
THE GIVING OF SUCH NOTICE AND THE EXPIRATION OF SUCH CURE PERIOD, IF
ANY, AS MAY BE REQUIRED UNDER THE APPLICABLE LOAN DOCUMENT), THE
MAKER AUTHORIZES ANY ATTORNEY ADMITTED TO PRACTICE BEFORE ANY
COURT OF RECORD IN THE UNITED STATES TO APPEAR ON BEHALF OF THE
MAKER IN ANY COURT IN ONE OR MORE PROCEEDINGS, OR BEFORE ANY
CLERK THEREOF OR PROTHONOTARY OR OTHER COURT OFFICIAL, AND TO
CONFESS JUDGMENT AGAINST THE MAKER, WITHOUT PRIOR NOTICE OR
OPPORTUNITY OF THE MAKER FOR PRIOR HEARING, IN FAVOR OF THE
HOLDER OF THIS NOTE IN THE FULL AMOUNT DUE ON THIS NOTE (INCLUDING
PRINCIPAL, ACCRUED INTEREST AND ANY AND ALL PENALTIES, FEES AND
COSTS) PLUS REASONABLE ATTORNEYS' FEES AND COURT COSTS. THE MAKER
WAIVES THE BENEFIT OF ANY AND EVERY STATUTE, ORDINANCE, OR RULE OF
COURT WHICH MAY BE LAWFULLY WAIVED CONFERRING UPON THE MAKER
ANY RIGHT OR PRIVILEGE OF EXEMPTION, HOMESTEAD RIGHTS, STAY OF
EXECUTION OR GARNISHMENT, OR SUPPLEMENTARY PROCEEDINGS, OR
OTHER RELIEF FROM THE ENFORCEMENT OR IMMEDIATE ENFORCEMENT OF
A JUDGMENT OR RELATED PROCEEDINGS ON A JUDGMENT. IF A COPY OF
THIS NOTE, VERIFIED BY AN OFFICIAL OR AN OFFICER OF THE FOLDER,
SHALL BE FILED IN ANY PROCEEDING OR ACTION WHEREIN JUDGMENT IS TO
BE CONFESSED, IT SHALL NOT BE NECESSARY TO FILE THE ORIGINAL HEREOF
AND SUCH VERIFIED COPIES SHALL BE SUFFICIENT WARRANT FOR ANY
ATTORNEY OF ANY COURT OF RECORD TO APPEAR FOR AND CONFESS
JUDGMENT AGAINST MAKER AS PROVIDED HEREIN. JUDGMENT MAY BE
CONFESSED FROM TIME TO TIME UNDER THE AFORESAID POWERS AND NO
SINGLE EXERCISE IN THE AFORESAID POWERS TO CONFESS JUDGMENT, OR A
SERIES OF JUDGMENTS, SHALL BE DEEMED TO EXHAUST THE POWER,
WHETHER OR NOT SUCH EXERCISE SHALL BE HELD BY ANY SUCH COURT TO
BE INVALID, VOIDABLE OR VOID, BUT THE POWER SHALL CONTINUE
UNDIMINISHED AND IT MAY BE EXERCISED FROM TIME TO TIME, AND IN THE
SAME OR DIFFERENT JURISDICTIONS, AS, AFTER AND AS THE HOLDER SHALL
ELECT, UNTIL SUCH TIME AS THE HOLDER SHALL HAVE RECEIVED PAYMENT
IN FULL OF ALL SUMS DUE HEREUNDER, TOGETHER WITH INTEREST, COSTS
AND FEES.
11. Interest Rate after Judgment. If judgment is entered against Maker on this Note, the
amount of the judgment entered ('Which may include principal, interest, fees and costs) shall bear
interest at the above described Default Rate, to be determined on the date of the entry of the
judgment.
12. Expenses of Collection. Should this Note be referred to an attorney for collection,
whether or not judgment has been confessed or suit has been filed, the Maker shall pay all of the
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Holder's reasonable costs, fees (including, but not limited to, reasonable attorneys' fees) and
expenses resulting from such referral.
13. Subsequent Holders. In the event that any Holder of this Note transfers this Note for
value, the Maker agrees that no subsequent Holder of this Note shall be subject to any claims or
defenses which the Maker may have against a prior Holder, all of which are waived as to the
subsequent Holder, and that all subsequent Holders shall have all of the rights of a Holder in due
course with respect to the Maker even though the subsequent Holder may not qualify, under
applicable law, absent this paragraph, as a Holder in due course.
14. Holder. As used in this Note, the term Holder shall refer to the Lender, and to any
other person, if any, who is in possession of this Note and to whom this Note has been indorsed,
whether to order, to bearer or in blank.
15. Waiver of Defects. The Maker hereby waives and releases all errors, defects and
imperfections of a procedural nature in any proceedings instituted by the Holder hereunder, as well
as all benefits that might accrue to the Maker by virtue of any present or future laws exempting any
property, real or personal, or any part of the proceeds arising from any sale of any such property,
from garnishment. attachment, levy or sale under execution, or providing for any stay of execution,
exemption from civil process, or extension of time for payment. The Maker agrees that any real
estate that may be levied upon pursuant to any writ of execution issued on any judgment by virtue
hereof, may be sold, in whole or in part, in any order desired by the Holder.
16. Waiver of Protest. The Maker, and all parties to this Note, whether maker., indorser
or guarantor, waive presentment, notice of dishonor and protest.
17. Extensions of Maturity. All parties to this Note, whether maker, indorser or
guarantor, agree that the maturity of this Note, or any payment due hereunder, may be extended at
any time or from time to time without releasing, discharging or affecting the liability of such party.
18. Notices. Any notice or demand required or permitted by or in connection with this
Note shall be given in the manner specified in the Agreement for the giving of notices under the
Agreement. Notwithstanding anything to the contrary, all notices and demands for payment from.
the Holder actually received in writing by the Maker shall be considered to be effective upon the
receipt thereof by the Maker regardless of the procedure or method utilized to accomplish delivery
thereof to the Maker.
19. Assignability. Subject to the limitations on assignment set forth in Section 11,6 of
the Agreement, this Note may be assigned by the Lender or any Holder at any time or from time to
time. The Lender or Holder shall notify the Maker, as soon as practicable, of the assignment, but
any failure to so notify shall not in any manner affect the obligations of the Maker to make any and
all payments required hereunder.
20. Bindina Nature. This Note shall inure to the benefit of and be enforceable by the
Lender and the Lender's successors and assigns and any other person to whom the Lender may grant
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..._ .
an interest in the Maker's obligations to the Lender, and shall be binding and enforceable against the
Maker and the Maker's personal representatives, successors and assigns.
2`1. Invalidity of M Part. If any provision or part of any provision of this Note shall for
any reason be held invalid, illegal or unenforceable in any respect, such invalidity, illegality or
unenforceabiiity shall not affect any other provisions of this Note and this Note shall be contained as
if such invalid, illegal or unenforceable provision or part thereof had never been contained herein,
but only to the extent of its invalidity, illegality or unenforceability.
22. Choice of Law. This Note shall be governed, construed and interpreted strictly in
accordance with the laws of the Commonwealth of. Pennsylvania.
23. Capitalized Terms. Capitalized terms, unless otherwise defined herein, shall have
the meanings attributed thereto in the Agreement, unless the context clearly requires a different
meaning.
24. Jurisdiction. The Maker hereby agrees and consents that any action or proceeding
arising out of or brought to enforce the provisions of this Note may be brought in the Court of
Common Pleas in Cumberland County, Pennsylvania, at the sole election of the Lender or the
Holder, and by the execution of this Note, the Maker irrevocably consents to the jurisdiction of any
such court.
IN WITNESS WHEREOF, the Maker has executed this Note specifically intending this
Note to constitute an instrument under seal.
ATTEST:
(Asst.) Secretary
(SEAL)
MAKER:
LIGHTST;Ort TD.
By:
Slagle, President
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COMMONWEALTH OF PENNSYLVANIA :
: SS
COUNTY OF FRANKLIN
Bradley Tanguay, being duly sworn according to law, deposes and says that he is Special
Assets Portfolio Manager for 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 Complaint
in Confession of Judgment are true and correct to the best of his knowledge, information and
belief.
Bradley Tanguay
Special Assets Portfolio Manager
Sworn to and Subscribed
before me this day
of 2012.
J•Iavl)
Notary Public
COMMONWEALTH of PENNSYLVANIA
Notarlel Seal
Christiana R. nMmons, Notary Publk
AY commisslon 001res Mwch 3 20i
M
Member, Penns*anla l?ssodation of
93%855_1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ORRSTOWN BANK NO. a _ ?{ O
vs. C?,w.ruxo-.?1
LIGHTSTYLES, LTD.
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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'S
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 - Striking Off Jud ent
(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
93968551
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.
(g) (1) A judgment shall not be stricken or opened because of a creditor's failure to
provide a debtor with instructions imposed by an existing statute, if any, regarding procedures to
follow to strike a judgment or regarding any rights available to an incorrectly identified debtor.
(2) Subdivision (g)(1) shall apply to (1) judgments entered prior to the effective
date of subdivision (g) which have not been stricken or opened as of the effective date and (2)
judgments entered on or after the effective date.
DILWORTH PAXSON LLP
BY: a?40 -/?
Eliza eth J. Goldstein, Esquire
Attorney for Plaintiff
93968551
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ORRSTOWN BANK
VS.
LIGHTSTYLES, LTD.
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA:
SS
NO. Q- L4 0 l S ?yl ?? N t,?
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COUNTY OF DAUPHIN
Elizabeth J. Goldstein, Esquire, attorney for Plaintiff, hereby certifies that the above-
captioned matter is not an action by a seller, holder or assignee arising out of a retail installment
sale, contract, or account.
Dilworth Paxson LLP
By:
646&AW-
Elizabeth J. Goldstein
Attorney for Plaintiff
Sworn to and Subscribed
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before me this / day
of _ ,,t , 2012.
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Notary ublic
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Deborah L. Julian, Notary Public
Susquehanna TWP•, Da P
My commission nas Member. Penrinwanla p radon of Notaries
93968551
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ORRSTOWN BANK
NO. IC'). k4 ()i. ef ol
vs.
LIGHTSTYLES, LTD.
CERTIFICATION OF NON-CONSUMER CREDIT TRANSACTION
I certify, pursuant to the penalties of 18 Pa.C.S. §4904 (pertaining to unsworn
falsification to authorities), that this judgment is not being entered by confession against a
natural person in connection with a "consumer credit transaction" as the same is defined in
Pa.R.C.P. 2950.
Dilworth Paxson LL/ P
By: A Ak? _
Eliza eth J. Goldstein, Esquire
Attorney for Plaintiff
Sworn to and Subscribed
before me /3 ?'' day
of , 2012.
NItary Public
COMMONWEALTH OF PENNSYLVANIA
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Notarial Seal
Deborah L. Julian, Notary Public
Susquehanna Twp., Dauphin County
My Commission E)Ores Oct. 20, 2014
Member. Pennsvivania Association of Notaries
93968551
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ORRSTOWN BANK
VS.
LIGHTSTYLES, LTD.
NO. 1 a-?(q(S elvi)
AFFIDAVIT OF BUSINESS OR COMMERCIAL TRANSACTION
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
Elizabeth J. Goldstein, Esquire, being duly sworn according to law, deposes and says that
she is attorney for Plaintiff named herein; that as such she is authorized to take this Affidavit on
its behalf; that the facts set forth herein are true and correct to the best of her knowledge,
information and belief; and that the facts set forth in the foregoing matter involve a business
transaction.
Sworn to and Subscribed
before me day
of , 2012.
No Public
jj ()F PENNSYLVANIA
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NoWal SOW
Deborah L Julian, NcbxY Pl b
Dr*in min pcpl?es n,+ 20.2014
Member. Pennsylvania Assodaa°n of Notaries
Dilworth Paxson LLP
By: rV i?w'
Elizabeth J. Goldstein, Esquire
Attorney for Plaintiff
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93968551
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ORRSTOWN BANK NO.
V3.
LIGHTSTYLES, LTD.
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF DAUPHIN
Elizabeth J. Goldstein, Esquire, attorney for Plaintiff, hereby certifies that the above-
captioned matter is not an action by a seller, holder or assignee arising out of a retail installment
sale, contract, or account.
Dilworth Paxson LLP
By:
Elizabeth J. Goldstein
Attorney for Plaintiff
Sworn to and Subscribed
before me this 13 day C
of I?,u ,,,4 , 2012. C,,,
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Notary P blic z _
COMMONWEALTH OF PENNSYLVANIA D Q
NotaMal Seat -< d
Deborah L. Julian, Notary Public
Susquoanna Twp., Dauphin County
CCnM Mon Expires Oct 20, 2014
Penla Aeioclation of Notaries
93968551
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ORRSTOWN BANK NO.
VS.
LIGHTSTYLES, LTD.
CERTIFICATION OF ADDRESSES
I hereby certify that the present address of the within named Judgment Creditor is 77 East
King Street, P.O. Box 250, Shippensburg, Franklin County, Pennsylvania 17257.
I hereby certify that the last known address of the Judgment Debtor was 1216 Claremont
Road, Carlisle, Cumberland County, Pennsylvania 17015.
Dilworth Paxson LLP
By:
Elizab th J. Goldstein, Esquire
Attorney for Plaintiff
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93968551
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ORRSTOWN BANK
NO.
vs.
LIGHTSTYLES, LTD.
ORDER FOR APPEARANCE
Kindly enter my appearance for Plaintiff, Orrstown Bank, and enter judgment against
Defendant, LIGHTSTYLES, LTD.
Dilworth Paxson LLP
By:
Eliza eth J. Goldstein, Esquire
Attorney for Plaintiff
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93968551
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ORRSTOWN BANK
No. )P_(40jS civil
vs.
LIGHTSTYLES, LTD.
PENNSYLVANIA RULE OF CIVIL PROCEDURE 236 NOTICE
Notice is hereby given that a judgment in the above-captioned matter has been entered
against you on \? b 2?. `D , 2012
By:
Prothonotary'
!!WOW
Deputy rothonotary
If you have any questions concerning the above, please contact:
Elizabeth J. Goldstein, Esquire
Dilworth Paxson LLP
112 Market St., Suite 800
Harrisburg, PA 17101
(717) 236-4812
93968551
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
ORRSTOWN BANK
vs.
LIGHTSTYLES, LTD.
NO. 12-4015
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PRAECIPE TO WITHDRAW JUDGMENT
TO THE PROTHONOTARY:
Kindly mark the judgment in the above-captioned case "withdrawn".
Respectfully submitted,
ELIZABETH J. GOLDSTEIN, P.C.
By: IZL --
Eliza eth J. Goldstein, Esquire
Attorney I.D. #73779
355 North 21" Street, Suite 202
Camp Hill, PA 17011
(717) 724-0266
Attorneys for Plaintiff
DATED: June 29, 2012
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9523298_1 p-A ??? "I '1 l
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 the same in the
United States Mail, Harrisburg, Pennsylvania with first-class postage, pre-paid as
follows:
Lawrence G. Frank, Esq.
212 Locust Street
Suite 500
PO Box 9500
Harrisburg, PA 17108-9500
Dilworth Paxson LLP
Dated: June 29, 2012 By: aj"w E izabeth J. Goldstein
Attorney I.D. #73779
355 North 21St Street, Suite 202
Camp Hill, PA 17011
(717) 724-0266
Attorneys for Plaintiff
9523298_1
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
1_1101, D, C 1101 l"14110
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Orrstown Bank
Case Number
vs.
Lightstyles LTD 2012-4015
SHERIFF'S RETURN OF SERVICE
06/29/2012 09:15 AM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on June 29,
2012 at 0915 hours this Complaint in Confession of Judgment upon defendant Lightstyles, LTD. is
returned not served per request from Attorney Elizabeth J. Goldstein.
SHERIFF COST: $28.45 SO ANSWERS,
June 29, 2012 RON R ANDERSON, SHERIFF