HomeMy WebLinkAbout12-4654F\FILES\Clients\8369 John Gross & Co18369.50 Strong Coffee Two\8369.50.com.confl.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
L. L.. ?J s" %.
5 PM, I" y. .
PENtISY LVIVNi
JOHN GROSS AND COMPANY, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
:NO. 2012 -4_5-q CIVIL TERM
STRONG COFFEE TWO, LLC,
d/b/a SAXBYS COFFEE,
Defendant
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the Credit Application and Personal Guarantee attached
as Exhibit "A" to the Complaint filed in the above-captioned case, we appear for Defendant Strong
Coffee Two, LLC, d/b/a Saxbys Coffee and confess judgment in favor of John Gross and Company,
Inc., against Strong Coffee Two, LLC, d/b/a Saxbys Coffee as of May 25, 2012, as follows:
Principal $6,869.32*
Costs of Suit (estimated) $ 500.00
Attorney Fees (estimated) $1,500.00
Total: $8,869.32*
*Plus interest per diem at $3.68, along with additional costs and fees incurred, until
paid in full.
Respectfully submitted:
MARTSON LAW OFFICES
By: (2 1i r /L_
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Pei fIA
?s aai?
JOHN GROSS AND COMPANY, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2012 - V4 SV CIVIL TERM
STRONG COFFEE TWO, LLC,
d/b/a SAXBYS COFFEE,
Defendant
COMPLAINT FOR CONFESSION OF JUDGMENT
John Gross and Company, Inc., by and through its undersigned counsel, hereby files this
Complaint for Confession of Judgment pursuant to Pa. R.C.P. Rule 2951 et seq., and in support
thereof, avers the following:
1. Plaintiff, John Gross and Company, Inc. ("Plaintiff'), is a Pennsylvania corporation
with a registered office address of 308 Cheryl Avenue, Mechanicsburg, Pennsylvania 17055.
2. Defendant, Strong Coffee Two, LLC, d/b/a Saxbys Coffee ("Defendant"), is a
Pennsylvania limited liability company with a business address of 804 Elizabeth Court, Collegeville,
Pennsylvania 19426.
3. On November 20, 2010, Defendant executed a Credit Application & Personal
Guarantee ("Credit Application") pursuant to which Plaintiff agreed to extend credit to Defendant, and
Defendant agreed to pay all purchases charged to Defendant's account. A true and correct copy of the
Credit Application is attached hereto and incorporated herein as Exhibit "A."
4. Pursuant to the terms and conditions of the Credit Application, failure of the
Defendant to pay within thirty (30) days of receipt of an invoice constitutes a default.
5. Defendant has defaulted under the Credit Application, by and including, but not
limited to, failing to pay invoices within thirty (30) days of receipt ("Default").
6. The Credit Application provides that Plaintiff, upon a Default by Defendant, may
confess judgment against Defendant for all sums due and owing thereunder.
7. The total surn due and owing under the Credit Application as of May 25, 2012, is
itemized as follows:
Principal $6,869.32*
Costs of Suit (estimated) $ 500.00
Attorney Fees (estimated) $1,500.00
Total: $8,869.32*
*Plus interest per diem at $3.68, along with additional costs and fees incurred, until
paid in full.
All conditions precedent have been satisfied to allow Plaintiff to confess judgment
against Defendant under the Credit Application.
9. Judgment has not been confessed against Defendant in any other jurisdiction under
the Credit Application.
10. Plaintiff is the holder of the Credit Application.
11. The Credit Application was executed and delivered in connection with a commercial
transaction, and judgment is not being entered by confession against a natural person in connection
with a consumer credit transaction.
12. The Credit Application has not been assigned.
WHEREFORE, John Gross and Company, Inc., requests that this Court enter judgment by
confession against Strong Coffee Two, LLC, d/b/a Saxbys Coffee, in the amount of $8,869.32, along
with interest accruing at the per diem rate of $3.68, and additional fees and costs as prayed for in the
Complaint.
Respectfully submitted,
MARTSON LAW OFFICES
By: (:? 4
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: 7/?SJ/ice Attorneys for Plaintiff
EXHIBIT "A"
39 Customer Name
LIa`l3a
Customet Number
Welcome
to the Family of -JOHN
Committed to the Success of our Customers
For over 50 years!
Credit Application & Personal Guarantee
400 Cheryl Avenue • P.O. Box 1189 • Mechanicsburg, PA 17055
717-766-2508 1-800-368-6800
2/06
JMPANY NAME f -o-a r- ' CD FFEE -rt jr> I_ LC-
NAME (DBA) (Z4 6 13YS CAFE PROPRIETOR
dMBER
;e check one of the following: X State Corporation registered to do business in FA 0 Sole Proprietorship 0 Partnership
?igth of Time Operating/Owning this Establishment 0 Do you: 0 Own )(Rent 0 Currently purchasing property
,APPROXIMATE CREDIT REQUIREMENTS ln, m0 NO. OF EMPLOYEES to
PENNSYLVANIA SALES TAX EXEMPTION NUMBER: If you hold a valid Pennsylvania Blanket Sales Tax Exemption Certificate
Please attach executed form Rev, 1220: Exemption certificate
SHIPPING BUSINESS ADDRESS BILLING
Address )Ca?S c'DFF0,b
City, state C(' Pro
Zip ( qLG ( Bus. Phone# (14-1 61-4--10?4
FAX# (_)
Merchandise receiving hours 4A' S pM
Special delivery instructions: ktoS(, (•j E XC V+ Nl,%t,, _
Contact Name: A4.4,Rr-, (4,jJ_TAA^-'
Address: ICI EU1 A I STY ST -
P.O. Box #
City, State CbQL%Ev<<-t-'6, 1A
Zip t TILf" Bus. Phone# ( jgq ) 6 F2-g S4 Z
FAX# L-_)
EMAIL MME - 1 S VM7- aN . t-'ET
NAME, ADDRESSES, PHONE NUMBERS OF ALL OWNERS/PARTNERS:
Name DAWO V0621 A_ 0202ulf Social Security # - . _ s License ate PA
Home Address_ ?? PE?? UR S NA4 4AV4, PA -Email
How long have you resided at this location? 214- Home Phone _,?
Name ?P,_? BAS-'T WAI'-J Social Security# - )rivers License ' State?
Home Address & 4 E'U-LA-9iTk -j-, Email 140%1' P (rEftzckA'• NE-T
How long have you resided at this location? L t 2 Home Phone -C
Name Social Security # Drivers License State
Home Address Email
How long have you resided at this location? Home Phone
Name Social Security # Drivers License State
Home Address Email
How long have you resided at this location? Home Phone
/J 1' REFERENCES
BUSINESS BANK 71) LY+JJ '
Name, Address, Phone ?-gcj W _ & 12MA.- T4b 3 r(Kk, IL-'(Mtn Mrtr)? r %OA 14?6z'
Contact Account # KM L+ '?' 703 O
PERSONAL BANK
Name, Address, Phone
Contact Account #
SUPPLIER REFERENCES
/,s: 1. Name ?oSS Phone#
Address ?i zCtS tir?L f,,?1r 147-71 2-"1
2. Name
Address
3. Name
Phone#
Address
TERMS AND CONDITIONS
In consideration for the extension of credit and intending to be legally bound hereby, the undersigned Buyer hereby agrees that the following terms will
govern any charge account established by John Gross & Co. (Seller) for Buyers benefit
1. Payment. Buyer hereby agrees to pay the Time Sale Price of purchases charged to Buyers account The Time Sale Price shall consist of the cash
sale price including applicable sales tax and delivery charges, if any, plus service charges and any finance charge which may accrue pursuant to paragraph
two (2) hereunder,
2. Past Due Accounts. Payment is due upon receipt. Failure to pay within 30 days of receipt ("the billing date") constitutes a default Buyer hereby agrees
that interest charges of 112% per month or 18% per annum will be assessed on any account balance which is not satisfied within 30 days of the Billing Date.
3. Seller's Remedies. In the case of Buyer's Default, Buyer's entire account balance shall become due and payable. Seller's waiver of any Default shall
not operate as a waiver of any other Default. If Buyer's account is referred for collection to an attorney, Buyer will pay, to the extent permitted by law,
reasonable attorney's fees and court costs incurred.
4. Seller's Discretion. The extension of temporary credit pursuant to this Agreement is within Seller's sole discretion and Seller may terminate this
Agreement any time and for any reason.
5. Credit Check Buyer hereby authorizes the firms and banking instttutions listed above to furnish any information requested by Seller to process this
application; and Buyer agrees that neither those firms nor their employees shall be liable for any claim of damages as a result of furnishing the requested
information.
6. Buyer shall pay Seller a service charge of $25.00 for each check returned by the Buyer's bank, unless said service charge would result in the
violation of the usury laws of the applicable jurisdiction.
7. Buyer shall notify Seller by certified mail immediately upon any change of ownership or change of Address of Buyer.
8. Buyer shall completely fill out all sections of the Credit Application before credit can be extended.
CONFESSION OF JUDGEMENT
I/We hereby irrevocably authorize and empower any prothonotary, clerk, or attorney of any court of record within the United States or elsewhere to appear for
me/us and, with or without declaration, to confess judgement at any time or times against each, any or all of us and In favor of the Seller for the amount
demanded by Seiler to any Past Due Account under this Credit Application and Agreement, plus Interest, costs of collection, and attorneys fees provided
therein; and for so doing, this Agreement or a copy thereof, verified by affidavit shall be sufficient warrant Uwe hereby release all errors and expressly waive
all rights to any stay of execution under any law or rule of court now In force or hereafter enacted. All of the foregoing promises are the joint and several
promises of me/us and shall bind me/us, my/our heir, succession anO assigns. (Me waive protest, demand and notice of nonpayment The authority granted
herein to confess judgment against me/us 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 hereunder. W Initial Inffial
?+ DISCLOSURE
A. I/we understand that the above constitutes a Confession of Judgment provision that would permit the Seller to enter judgment against me/us in court, after
a failure to pay on demand any Past Due Account, without advance notice to metus and without offering me/us an opportunity to defend against the entry of
judgment. In executing the Agreement, being fully aware of my/our rights to advance notice and to a hearing to contest the validity of any Judgment or other
claims that the Seller may assert against me/us.. I/we am knowingly, Intelligently and voluntarily waiving these rights, including any right to advance notice of
the entry of judgment, and i/we expressly agree and consent to the Seller's entering judgment against me/us by confession as provided for in this Confession
of Judgment provision.
B. Itwe further understand that in addition to giving the Seller the right to enter judgment against me/us without advance notice or a hearing, this Confession
of Judgment also contains language that would permit the Seller, after entry of judgment, to execute on the judgment by foreclosing upon, attaching, levying
on, taking possession of or otherwise seizing my/our property, in full or partial payment of the judgment. Being fully aware of my rights to advance notice and
a hearing after judgment is entered and before execution on the judgment, I/we am knowingly, intelligently and voluntarily waiving these rights, and I/we
expressly agree and consent to the Seller's executing on the judgment, in any manner permitted by applicable state and federal law.
C. I/we certify that. a representative of the Seller specifically called this Confession of judgment to my/our attention.
D. I/we hereby certify that my/our annual income exceeds $10,000; that I/we received a copy hereof at the time of signing. L )V Initial Initial
Business name: S'j`R4?at5
Signature Title ?Fol- QI//t+FSt D F,c?T
Print Signed Name bAV 1.4 Vb/JflF-&r-Aku/N6 Date (1, -Lot In
I certify the information provided in this credit Application and agreement Is true and correct I authorize JOHN GrfOSS to verify the information provided and
to contact the references listed.
Phone#
PERSONAL GUARANTEE OF PAYMENT
for and in consideration of your extending credit at my request to (the Buyer)
,pally guarantee prompt payment of any obligation of the company to John Gross & Co., and affiliated entities (`SELLER"), whether now existing or
jinafter incurred, and 1 further agree to bind myself to pay on demand any sum which is due by the Buyer to Seller whenever the Buyer fails to pay the
ne, it is understood that this guarantee shall be an absolute, continuing unlimited and Irrevocable guarantee for such indebtedness of the Buyer.
I expressly waive presentment, unlimited demand, protest, notice of protest, dishonor, diligence„ notice of default or nonpayment, notice of acceptance
of this guaranty, notice of the extending of any guaranteed indebtedness already or hereafter contracted for by the Buyer, notice of any modification or renew-
al of any credit agreement evidencing the indebtedness hereby guaranteed, notice of any renewal or extension of such indebtness. I further waive any right
to require Seller to proceed against, or make any effort at collection of the guaranteed indebtedness from, the Buyer or any other party liable for such
Indebtedness.
If the guaranteed indebtedness is not paid by me when due, and this guaranty is placed in the hands of an attorney for collection or suit is brought
hereon, or it is enforced through any judicial proceeding whatsoever, 1 shall pay all reasonable attorneys' fees and court costs incurred by Seller.
In the event more than one party executes this guaranty as a guarantor, then such guarantor agrees to be jointly and severally liable for the guaranteed
indebtedness, and in all instances herein, the singular shall be construed to include the plural.
X X
Guarantor/Surety Date Guarantor/Surety Date
Home Address
(If different from front)
Home Address
(If different from front)
OFFICE USE ONLY
Sales Person 1--Wc l0-i?ll-- Special Instructions
Level Type Account ?rceTerms 30 Limit
Approved By
400 Chery.
717-766-,?_
VERIFICATION
I, Brian Gross, acknowledge I have the authority to execute this Verification on behalf of
John Gross & Company and certify the foregoing Complaint in Confession of Judgment is based
upon information which has been gathered by my counsel in the preparation of the lawsuit. The
language of this Complaint is that of counsel and not my own. I have read the document and to the
extent the Complaint is based upon information which I have given to my counsel, it is true and
correct to the best of my knowledge, information and belief. To the extent the content of the
Complaint is that of counsel, I have relied upon counsel in making this Verification.
This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904 relating
to unworn falsification to authorities, which provides that if I knowingly make false averments, I
may be subject to criminal penalties.
JOHN GROSS & COMPANY
By:
F:1FILES\Cllenuu769 John Gma @ C04369.30 drone coffee Twd\1369.50.*=.omn.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
t F' OT i
JU1- 25 PH 12•
l'U MBEF;E A,i`iJ C 0 U PENNSYLVANIA
JOHN GROSS AND COMPANY, INC.,
Plaintiff
V.
STRONG COFFEE TWO, LLC,
d/b/a SAXBYS COFFEE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2012 - ? ? 5-X CIVIL TERM
NOTICES IN CONNECTION WITH JUDGMENTS BY CONFESSION
REQUIRED BY 42 PA. C.S.A. §2737.1. (Act 105 of 2000)
To: Defendant
PURSUANT TO 42 PA. C.S.A. SECTION 273 IF YOU HAVE BEEN INCORRECTLY
IDENTIFIED AND HAD A CONFESSION OR JUDGMENT ENTERED AGAINST YOU,
YOU ARE ENTITLED TO COSTS AND REASONABLE ATTORNEY FEES AS
DETERMINED BY THE COURT.
INSTRUCTIONS REGARDING THE PROCEDURE TO STRIKE THE CONFESSED
JUDGMENT ARE SET FORTH BELOW:
Pennsylvania Rule of Civil Procedure 2959 - Striking 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 not
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 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 in 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 are 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.
You may have other rights available to you other than as set forth in this notice. You
should take this paper to your lawyer at once. If you do not have a lawyer, go to or telephone
the office set forth below. This office can provide you with information about hiring a lawyer.
If you cannot afford to hire a lawyer, this office may be able to provide you with
information about agencies that may offer legal services to eligible persons at a reduced fee or
no fee.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
tip i1t"
12 ..UL 25 PM 12. 3?-
CUM8ERLA1W C0Ui",JY
PENNSYLVANIA
JOHN GROSS AND COMPANY, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 2012 - %
STRONG COFFEE TWO, LLC,
d/b/a SAXBYS COFFEE,
Defendant
CERTIFICATE OF RESIDENCE
We hereby certify that the last known address of the Defendant is:
Strong Coffee Two, LLC
d/b/a Saxbys Coffee
804 Elizabeth Court
Collegeville, PA 19426
CIVIL TERM
The address of Plaintiff is: 308 Cheryl Avenue, Mechanicsburg, PA 17055
MARTSON LAW OFFICES
Y
Christopher E. Rice, Esquire
Seth T. Mosebey, Esquire
Date: J?/j2 Attorneys for Plaintiff
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ZA112 JUL 2S PM 12. 33
2
CUMBERLANID CvU iT i'
PENNSYLVANIA
JOHN GROSS AND COMPANY, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
STRONG COFFEE TWO, LLC,
d/b/a SAXBYS COFFEE,
Defendant
NO. 2012- y??y
AFFIDAVIT
CIVIL TERM
I, Christopher E. Rice, Esquire, attorney for Plaintiff, hereby certify, that to the best of my
knowledge, that the Confession of Judgment for Money attached is not being entered against a
natural person in connection with a consumer credit transaction.
(? - "! '?7 /' 5;: - te -
Sworn to and subscribed
before me this aS?k day of July, 2012.
"/, L ) ?61, r-;L a,
N? taj?/Public
Christopher E. Rice, Esquire
COM WE6M OF Pir NSYLVANIA
NOW41 $eal
Mary M. Price, Notary Pubk
CarlWe Moro, Cumberland County
My Commission Ecp has Aug. 18, 2015
MEMBER, PENKnVANIA ASSOQATION OF NOTARIES
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
#.
2612 JUL 25 PM 12: 38
PENNSYLVANIA
JOHN GROSS AND COMPANY, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2012 - c?G 5 t' CIVIL TERM
STRONG COFFEE TWO, LLC, /
d/b/a SAXBYS COFFEE,
Defendant
AFFIDAVIT AS TO MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA )
:SS.
COUNTY OF CUMBERLAND )
Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he
has authority to make this affidavit on behalf of his client, and to the best of his knowledge,
information and belief, the Defendant Strong Coffee Two, LLC, d/b/a Saxbys Coffee is not in the
military service of the United States of America, that he has knowledge that Strong Coffee Two,
LLC, has an address of 804 Elizabeth Court, Collegeville, Pennsylvania 19426.
(29,01- 52
Christopher E. Rice, Esquire
Sworn to and subscribed before me
this day of July, 2012.
L441 I j"
It-j"t'tt4) 77 OAI.-?.,
o ublic,
yWEALni OF PENNSYLVANIA
NOW&i Seal
public
Mary M. nd CountY
CadWe am Aug. 18, 2015
MEMBER, PENNm VAMA ASSOCIATION OF NOTARIES
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
JOHN GROSS AND COMPANY, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2012 - qY y
STRONG COFFEE TWO, LLC,
d/b/a SAXBYS COFFEE
Defendant
NOTICE OF ENTRY OF JUDGMENT
PURSUANT TO PA. R.C.P. NO. 236
To: Strong Coffee Two, LLC
d/b/a Saxbys Coffee
804 Elizabeth Court
Collegeville, PA 19426
CIVIL TERM
You are hereby notified that on judgment by confession was
entered against you in the above-captioned case in favor of John Gross and Company, Inc., as
follows:
Principal $6,869.32*
Costs of Suit (estimated) $ 500.00
Attorney Fees (estimated) $1,500.00
Total: $8,869.32*
*Plus interest per diem at $3.68, along with additional costs and fees incurred, until
paid in full.
S.
Date:
onotary
F:\FILES\Clients\8369 John Gross&Co\8369.50 Strong Coffee Two\8369.50.pra.wpd -
Christopher E. Rice, Esquire 0F i
Attorney I.D. No. 90916 �` ' 1 Nile? ,
Seth T. Mosebey, Esquire 1113 5EP 18
Attorney I.D. No. 203046 Pal 2' 10
MARTSON LAW OFFICES CUMBERLAND 'COUNTY
10 East High Street PENNSYLVANIA
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
JOHN GROSS AND COMPANY, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2012 - 4654 CIVIL TERM
STRONG COFFEE TWO, LLC,
d/b/a SAXBYS COFFEE, :
Defendant
PRAECIPE
To the Prothonotary:
Please mark the judgment in the above-referenced matter satisfied and the action
discontinued.
MARTSON LAW OFFICES
By:
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date:
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent for Martson Deardorff Williams Otto Gilroy &
Faller,hereby certify that a copy of the foregoing Praecipe was served this date by depositing same
in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Gary Stein, Esquire
O'DONNELL WEISS & MATTEI, P.C.
41 East High Street
Pottstown, PA 19464
MARTSON LAW OFFICES
By: ,
4r Y Price
Ten st High Street
Carlisle, PA 17013
(717) 243-3341
Dated: