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Home My WebLink About04-5484BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Attorneys for Plaintiff Identification No. 32493 Treeview Corporate Center, Suite 100 2 Meridian Boulevard Wyomissing, PA 19610 (610) 374-8377 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MANUFACTURERS AND TRADERS TRUST COMPANY, successor by merger to Keystone Financial Bank, N.A., Plaintiff vs. NO. 99-5163 ASSOCIATED PERIODONTISTS, INC., 4 *-- Defendant : ACTION IN CONFESSION OF :JUDGMENT PRAECIPE FOR WRIT OF REVIVAL (ADVERSE) OF JUDGMENT TO THE PROTHONOTARY: Issue Writ of Revival (Adverse) of Judgment entered to No. 99-5163 and index it in the judgment indexed against Associated Periodontists Inc. in the amount of $32,070.83, plus costs of this action. BINGAMAN, HESS, COBLENTZ & BELL P.C. By: Mark G. Yoder, Esquire Attorneys for Plaintiff Date: October 28, 2004 233810 'M I- i 'PIT' Fn V-) fi ?- tN Q BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Attorneys for Plaintiff Identification No. 32493 Treeview Corporate Center, Suite 100 2 Meridian Boulevard Wyomissing, PA 19610 (610) 374-8377 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MANUFACTURERS AND TRADERS TRUST COMPANY, successor by merger to Keystone Financial Bank, N.A., Plaintiff vs. NO. 99-5163 04-5484 CIVIL TERM ASSOCIATED PERIODONTISTS, INC., Defendant : ACTION IN CONFESSION OF :JUDGMENT WRIT OF REVIVAL (ADVERSE) TO: ASSOCIATED PERIODONTISTS, INC. (1) You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to No. 99-5163, Cumberland County Court of Common Pleas. (2) The Plaintiff claims that the amount due and unpaid is $32,070.83, plus costs of this action. (3) You are required within twenty (20) days after service of this writ to file an answer or otherwise plead to this writ. If you fail to do so judgment of revival will be entered. Costs: $34.50 Pd Atty $ 1.00 Co. Curtis R. Long PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA ?By: '4 n-? D P.C2?"2'r?J Deputy Date: October 29, 2004 233810 BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Attorneys for Plaintiff Identification No. 32493 Treeview Corporate Center, Suite 100 2 Meridian Boulevard Wyomissing, PA 19610 (610) 374-8377 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MANUFACTURERS AND TRADERS NO. 99-5163 TRUST COMPANY, successor by merger to Keystone Financial Bank, N.A., Plaintiff vs. ASSOCIATED PERIODONTISTS, INC., ACTION IN CONFESSION OF Defendant JUDGMENT SHERIFF INSTRUCTIONS TO THE SHERIFF OF CUMBERLAND COUNTY, PA: Kindly serve the Writ of Revival upon the person in charge at Defendant Associated Periodontists, Inc. place of business located at 3461 Market Street, Suite 304, Camp Hill, PA 17011 and make return of service upon the undersigned. BINGAMAN, HESS, COBLENTZ & BELL,P.C, By: /"'P? ?" ??? Mark G. Yoder, Esquire Attorneys for Plaintiff Date: October 28, 2004 233810 BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Attorneys for Plaintiff Identification No. 32493 Treeview Corporate Center, Suite 100 2 Meridian Boulevard Wyomissing, PA 19610 (610) 374-8377 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MANUFACTURERS AND TRADERS TRUST COMPANY, successor by merger to Keystone Financial Bank, N.A., Plaintiff vs. : NO. 99-5163 044 - S?SIPY (2,-0, l ASSOCIATED PERIODONTISTS, INC., Defendant : ACTION IN CONFESSION OF :JUDGMENT PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly enter judgment against Defendant, Associated Periodontists, Inc. for failure to plead to Plaintiffs Writ of Revival (Adverse), in the amount of $32,070.83, plus costs of this action. I hereby certify to the best of my knowledge and belief as follows: 1. The plaintiffs true and correct address is 50 North 5th Street, 5th Floor, P.O. Box 15210, Reading, PA 19612. 2. The last known mailing address of Defendant, Associated Periodontists, Inc. is Atrium West, 3461 Market Street, Suite 304, Camp Hill, PA 17011. BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: zv? -,,- Mark G. Yoder, Esquire Attorneys for Plaintiff 233810 BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Attorneys for Plaintiff Identification No. 32493 Treeview Corporate Center, Suite 100 2 Meridian Boulevard Wyomissing, PA 19610 (610) 374-8377 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MANUFACTURERS AND TRADERS TRUST COMPANY, successor by merger to Keystone Financial Bank, N.A., Plaintiff vs. ASSOCIATED PERIODONTISTS, INC., Defendant NO. 99-5163 Cam!- Z-gpq ACTION IN CONFESSION OF :JUDGMENT CERTIFICATION OF MAILING OF 237.1 NOTICE The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the Defendant, Associated Periodontists, Inc. in this matter was mailed to the Defendant after the default occurred and at least ten days prior to the filing of the praecipe for entry of judgment pursuant to Pa.R.C.P. 237.1. A true and correct copy of that notice is attached hereto as Exhibit "A" and made a part of this certification. BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Z-1,114 ?i Mark G. Yoder, Esquire Attorneys for Plaintiff 233810 FILE COM BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Attorneys for Plaintiff Identification No. 32493 Treeview Corporate Center, Suite 100 2 Meridian Boulevard, Wyomissing, PA 19610 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MANUFACTURERS AND TRADERS NO. 99-5163 TRUST COMPANY, successor by merger to 0L,! S LI Keystone Financial Bank, N.A., Plaintiff CIVIL ACTION - LAW vs. ASSOCIATED PERIODONTISTS, INC., : ACTION IN CONFESSION OF Defendant :JUDGMENT IMPORTANT NOTICE TO: ASSOCIATED PERIODONTISTS, INC. Atrium West 3461 Market Street, Suite 304 Camp Hill, PA 17011 Date: November 29, 2004 ASSOCIATED PERIODONTISTS, INC. IS IN DEFAULT BECAUSE IT HAS FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT ITS DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST IT. UNLESS ASSOCIATED PERIODONTISTS, INC. ACTS WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST IT WITHOUT A HEARING AND IT MAY LOSE ITS PROPERTY OR OTHER IMPORTANT RIGHTS. ASSOCIATED PERIODONTISTS, INC. SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF IT DOES NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE IT CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 800-990-91081717-249-3166 BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Attorneys for Plaintiff CC' James T. Grady, M&T Bank 233810 SHERIFF'S RETURN - REGULAR CASE NO: 2004-05484 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS TRUS VS ASSOCIATED PERIODONTISTS INC J. MICHAEL ICKES , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF REVIVAL was served upon ASSOCIATED PERIODONTISTS INC DEFENDANT the , at 1017:00 HOURS, on the 3rd day of November-, 2004 at 3461 MARKET STREET CAMP HILL, PA 17011 SUITE 304 by handing to MARVIN BERGER, PRESIDENT, ADULT IN CHARGE a true and attested copy of WRIT OF REVIVAL together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.10 Affidavit .00 Surcharge 10.00 .00 39.10 Sworn and Subscribed to before me this day of o?i*tl? A.D. y9 Prot onotary? Q-J--- So Answers: R. Thomas Kline 11/04/2004 BINGAMAN HESS COBLENTZ BELL By. &J"Lu", Deputy Sheriff COURT OF COMMON PLEAS COUNTY OF CUMBERLAND STATE OF PENNSYLANIA Manufacturers and Traders Trust Company, Successor by merger to Keystone Financial Bank, N.A. Plaintiff, Case No. 04-5484 -vs- ASSIGNMENT OF JUDGMENT Associated Periodontists, Inc., Defendant THIS ASSIGNMENT OF JUDGMENT (this "Assignment") is made by MANUFACTURERS AND TRADERS TRUST COMPANY, for itself and its predecessors in interest, whose address is One Fountain Plaza, Buffalo, New York 14203-1495 ("Assignor"), to PRAMCO III, LLC, whose address is 6894 Pittsford- Palmyra Road, 200 CrossKeys Office Park, Suite 230, Fairport, New York 14450 ("Assignee"), pursuant to the terms of that certain Asset Sale Agreement dated October 19, 2005 (the "Sale Agreement") between Assignor and Assignee. Capitalized terms used herein and not otherwise defined shall have the meanings ascribed to them in the Sale Agreement. THIS ASSIGNMENT WITNESSES THAT, in consideration of Ten Dollars ($10.00) and other good and valuable consideration paid by Assignee, Assignor hereby assigns, transfers, sets over and conveys, effective as of October 27, 2005, to Assignee and its successors and assigns, without recourse and without representation or warranty, whether express, implied or created by operation of law, except as expressly set forth in the Sale Agreement, the following: That certain Confession of Judgment dated August 23, 1999 entered in connection with the captioned action, original Case No. 99-5163, which was revived pursuant to that certain Praecipe for Judgment Against Defendant for Failure to Plead filed December 15, 2004, copies of which documents are attached hereto as Exhibit "A" ("Judgment"), together with such other documents, agreements, instruments and other collateral that evidence, secure or otherwise relate to Assignor's right, title or interest in and to the Judgment. THIS ASSIGNMENT FURTHER WITNESSES THAT Assignor hereby conveys and quitclaims to Assignee any and all right and interest it might have in the Judgment, and hereby joins in the conveyance of the Judgment to Assignee, without recourse and without representation or warranty, whether express, implied or created by operation of law, except as expressly set forth in the Sale Agreement. S:TOANS\Company 54?54250050\Assignment of Judgment.doc IN WITNESS WHEREOF, Assignor has caused this Assignment to be executed and delivered by its duly authorized agent as of the 27th day of October, 2005. MANUFACTURERS AND TRADERS TRUST COMPANY, as successor to Keystone Financial Bank, N.A., as Assignor Witness By: Witness Timothy P. Sheehan Its Authorized Agent ACKNOWLEDGMENT STATE OF NEW YORK ) )SS.: COUNTY OF MONROE ) On the I l day of April, 2006, before me, the undersigned, personally appeared Timothy P. Sheehan, personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his capacity, and that by his signature on the instrument, the individual, or the person upon behalf of which the individual acted, executed the instrument. Notary f peermtssion ate 0i five Torn County February 20, 20 -7 SALOANS\Company 5A54250050W ssignment of Judgment.do .FE9-07-2006 TUE 02!19 PM LAW OFFICES OF BHCB 10/19/2004 12:51 FAR 810 820 3722 PRO SEARCH R EYSTONX FINANCIAL BANK N.A. PLtfutiff - FAX NO, 6103763105 P. 07 0002/008 IN TITS COURT OF COMMON PLEAS COUNTY OF CUM ERLAND COM MONWULM OF MNS'YL'PANIA VS. CIM AMON LAW ASSOCTATICD PERIODONTISTS, INC., Defendant CNN TERM 1999- SI63 CONFESSION OF NDGMNT Pursuant to the Warrant of Attorney contained in tho Aforementioued Promissory Notc, the original or copy of which is attached to the Complaint filed in this action, I appear for the Plaintiff and confess judgment in favor of Plaintiff and against the Defendants, Associated Periodontists, Inc., as follows, Principal S54,811.35 Interest to 6-13-99 $ 957.84 Late Charges $ 211.24 Attorney's Fees $ 5,598.04 TOTAL S 61,578.47 with interest from Sane 13, M% on the principal sum of $54,811.35 at the rate of 9.250 % per annum RespeeftHy submitted, Duncan 8t H pp. C. Dated:-?3 Wt am quire PA M q 7,1090 Attorney for Plaintiff . ..FEB-07-2006 TUE 02,18 PM LAW OFFICES OF BHCB FAX NO. 6103763105 P. 02 BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Identification No. 32493 Treeview Corporate Center, Suite 100 2 Meridian Boulevard Wyomissing, PA 19610 (610) 374-8377 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MANUFACTURERS AND TRADERS NO. 99-5163 TRUST COMPANY, successor by merger to Keystone Financial Bank, N.A., Ou _ sypef ?eu( Plaintiff vs. ASSOCIATED PERIODONTISTS, INC., : ACTION IN CONFESSION OF Defendant :JUDGMENT PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly enter judgment against Defendant, Associated Periodontists, Inc. for failure, to plead to Plaintiffs Writ of Revival (Adverse), in the amount of $32,070.83, plus costs of this action. I hereby certify to the best of my knowledge and belief as follows: 1. The plaintiffs true and correct address is 50 North 51" Street, 5t° Floor, P.O. Box 15210, Reading, PA 19612. 2, The last known mailing address of Defendant, Associated Periodontists, Inc. is Atrium West, 3461 Market Street, Suite 304, Camp Hill, PA 17011. BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: 1.7 Mark G. Yoder, Esquire Attorneys for Plaintiff 233810 ?? ?,. ?, ?? ? ?? w ? ,-- .? ? 4., L ?'? ?._ ?; TRAMCOIII LLC vs. ASSOCIATED PERIODONTISTS INC. No. CIVIL TERM 99-516 PRAECIPE for WRIT OF EXECUTION (MONEY JUDGMENTS) CONFESSED JUDGMENT PRAECIPE FOR WRIT OF EXECUTION - CONFESSED JUDGMENT To the Prothonotary: ISSUE WRIT pF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Associated Periodontists, Inc., Defendant (3) and against Garnishee (s); (4) and index this writ (a) against Associated Periodontists Inc. (b) against as a hs pendens against the real property of the defendant (s) in the name of the Garnishee (s) (Specifically describe property per attached property description): 4(- (5) Amount due $ d7O.P3 Interest from the j8 3 . G Co 6/13/99 Plus costs. Dated d -c--?bF GV W for Plaintiff(s) 54286 NOTE Under Paragraph (1) when the writ is directed to the sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph (3) above should be completed only if a named garnishee is to be included in the writ. Paragraph (4) (a) should be completed only if indexing of the execution in the county of issuance, is desired as authorized by Rule 3104(a). When the writ issues to another county indexing is required as of course in that county by the prothonotary. See Rule 3104(b). Paragraph (4) (b) should be completed only if real property in the name of gamishee is attached and indexing as a Iis pendens is desired. See Rule 3104(c). No. Civil Term 1999-5163 li Eu, OF In the Court of Common Pleas of 2,21FEB 28 8, 35Cumberland County, Pennsylvania iV PRAMCO III, LLC 230 Crosskeys Office Park Fairport, NY 14450 Plaintiff vs. 7415 bb c- ? ODONTISTS, INC. SU ? 06 3; . ii ASSOCIATED PERI 3461 Market Street, Suite 304 . SO r? f Camp Hill, PA 17011 Defendant PRAECIPE FOR WRIT OF EXECUTION - CONFESSED JUDGMENT (Money Judgments) Pa. R.C.P. 3101 to 3149 etc. '% C'6 4. s'o 4,4,- Kaplin, Stewart, Meloff, Reiter and Stein, P.C. 910 Harvest Drive, Bldg. 640 Post Office Box 3037 C K-If a 3 ?ou Blue Bell, PA 19422 (610)260-6000 q 312 KAPfinj§"rt February 22, 2007 Sheriff's Office of Cumberland County One Courthouse Square Carlisle, PA 17013 RE: Keystone Financial Bank, N.A. v Associated Periodontists, Inc. C.C.P. No. 1999-5163 Dear Sir/Madam: William J. Levant, Esquire represents the Plaintiff in the above matter. Enclosed are: Nancy C. Aiken Direct Dial: (610) 941-2543 Direct Fax: (610) 684-2101 Email: naiken@kaplaw.com www.kaplaw.com • A time stamped copy of a Praecipe for Voluntary Substitution of Plaintiff Under Pa.R.C.P. 2342(a); • A time stamped copy of the Writ of Execution, with required notices attached; • A check payable to the Sheriff in the amount of $150.00, representing a deposit against his costs to serve the Writ and levy upon the property; • A small, self addressed stamped envelope. Kindly serve the Writ Package with required notices and the Praecipe for Substitution upon the Defendant. You are directed to levy upon the property of the Defendant and to sell its interest therein; please levy the Defendant's interest in all articles of personal property capable of levy under the Rules of Civil Procedure found on the premises of 3461 Market Street, Suite 304, Camp Hill, Cumberland County, PA 17011. Please call me if you have any questions about the above. Sincerely, C. en 4egal NCA:nca Enclosures cc: William J. Levant, Esquire (w/o encl.) Kaplan Stewart Melon Reiter & Stein, PC Union Meeting Corporate Center Offices in: 910 Harvest Drive, P.O. Box 3037 Pennsylvania Blue Bell, PA 19422-0765 New Jersey (610) 260-6000 tel WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5484 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRAMCO III, LLC Plaintiff (s) From ASSOCIATED PERIODONTISTS, INC., 3461 Market Street, Suite 304, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell defendant's interest in all articles of personal property capable of levy under the RCP found on the premises of 3461 Market Street, Suite 304, CampHill, Cumberland County, PA 17011 . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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 any property of the defendant (s) or otherwise disposing thereof; (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 $32,070.83 Interest $4,303.66 Atty's Comm % Atty Paid $32.00 Plaintiff Paid Date: February 28, 2007 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs C s R. Long, P onot By: REQUESTING PARTY: Name William J. Levant, Esquire Address: 910 Harvest Drive PO Box 3037 Blue Bell, PA 19422-0765 Attorney for: Plaintiffs Telephone: 610-260-6000 Supreme Court ID No. 54286 Deputy KAPLIN STEWART MELOFF REITER & STEIN, P.C. By: William J. Levant, Esquire I.D. No. 54286 910 Harvest Drive, P. 0. Box 3037 Blue Bell, PA 19422-0765 (610) 260-6000 KEYSTONE FINANCIAL BANK, N.A. Plaintiff, V. IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA ASSOCIATED PERIODONTISTS, INC. CIVIL ACTION LAW Defendant. CIVIL TERM '9-+63 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of PRAMCO III, LLC, Plaintiff by voluntary substitution. KAP STE ART M LOFF REITER & STEIN, P.C. C? Y? i ire Dated: Z NCA/6611/81/963626 1 02/21/2007 12:34 PM ' C r. j U-1 co s'i't KAPLIN STEWART MELOFF REITER & STEIN, P.C. By: William J. Levant, Esquire I.D. No. 54286 910 Harvest Drive, P.O. Box 3037 Blue Bell, PA 19422-0765 (610) 260-6000 KEYSTONE FINANCIAL BANK, N.A. Plaintiff, V. : IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA ASSOCIATED PERIODONTISTS, INC. CIVIL ACTION LAW Defendant. CIVIL TERM f9994463 Ow - S-c PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAIN' UNDER PA.R.C.P. 2352(a) TO THE PROTHONOTARY: Kindly file of record the Praecipe of PRAMCO III, LLC for Voluntary Substitution under Pa.R.C.P. 2352(a) and attached Statement of the Material Facts in Support of Voluntary Substitution, Verification, Certification of Service and Entry of Appearance. The address for the Plaintiff is: 200 Crosskeys Office Park 6894 Pittsford Palmyra Road, Ste. 230 Fairport, NY 14450 PLIN EW T MELOFF REITER & STEIN, P.C. By: -Willi ev ?` Date: La f 1 --7 NCA/6611/81/963626_1 02/21/2007 12:34 PM KAPLIN STEWART MELOFF REITER & STEIN, P.C. By: William J. Levant, Esquire I.D. No. 54286 910 Harvest Drive, P.O. Box 3037 Blue Bell, PA 19422-0765 (610) 260-6000 KEYSTONE FINANCIAL BANK, N.A. IN THE COURT OF COMMON PLEAS Plaintiff, : COUNTY OF CUMBERLAND V. : COMMONWEALTH OF PENNSYLVANIA ASSOCIATED PERIODONTISTS, INC. CIVIL ACTION LAW Defendant. CIVIL TERM 1999-5163 STATEMENT OF THE MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSTITUTION UNDER Pa R C P 2352(a) PRAMCO, III, LLC, by counsel, hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: 1. The above-captioned case is a confession of judgment. 2. The subject of the above-captioned case is a Commercial Guaranty and Promissory Note, both dated January 13, 1999 in favor of Keystone Financial Bank, N.A., in the original principal amount of $58,000.00. 3. The original Plaintiff is MANUFACTURERS AND TRADERS TRUST COMPANY, successor by merger to Keystone Financial Bank, N.A. 4. PRAMCO III, LLC is succeeding to the interest of Manufacturers and Traders Trust Company by Assignment dated October 27, 2005, a?copy of which is attached- hereto, and, is hereby voluntarily substituted as Plaintiff in the above-captioned matter. NCA/6611 /81 /963626 1 02/21/2007 12:34 PM KAPLIN STEWART MELOFF REITER & STEIN, P.C. By: William J. Levant, Esquire I.D. No. 54286 910 Harvest Drive, P.O. Box 3037 Blue Bell, PA 19422-0765 (610) 260-6000 KEYSTONE FINANCIAL BANK, N.A. IN THE COURT OF COMMON PLEAS Plaintiff, V. COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA ASSOCIATED PERIODONTISTS, INC. Defendant. CIVIL ACTION LAW CIVIL TERM 1999-5163 CERTIFICATION OF SERVICE I, William J. Levant, Esquire, under penalty of 18 P.S. §4904, do hereby certify that I caused true and correct copies of the foregoing Praecipe for Voluntary Substitution and all supporting papers attached hereto to be sent, via First Class U.S. Mail to: ASSOCIATED PERIODONTISTS, INC. 3461 Market Street, Suite 304 Camp Hill, PA 17011 STEWMT MELOFF REITER & STEIN, P.C. Dated: 2 I/C7 NCA/6611 /81 /963626_ 1 02/21/2007 12:34 PM c.. ? ? -,., `n rTr T ' ? rrz _ ? _ . t'U r _ _ ;-ra ,-: a of - .? r' ? ::_a ,.? ?_, ? ?. ?. "'' ?= ??? .r ..? R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Advance Costs: 150.00 Sheriff s Costs 78.38 Docketing 18.00 74.62 Poundage 1.48 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 01/07/08 Mileage 14.40 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Certified Mail. Postage Garnishee ? l '?/ ?9. TOTAL 75.38 ? So Answers, 12. Thomas ine, By ?t-tJJ ;p e 93) y ')?d3/b? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5484 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRAMCO III, LLC Plaintiff (s) From ASSOCIATED PERIODONTISTS, INC., 3461 Market Street, Suite 304, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell defendant's interest in all articles of personal property capable of levy under the RCP found on the premises of 3461 Market Street, Suite 304, CampHill, Cumberland County, PA 17011 . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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 any property of the defendant (s) or otherwise disposing thereof, (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 $32,070.83 Interest $4,303.66 Atty's Comm % Atty Paid $32.00 Plaintiff Paid Date: February 28, 2007 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs C is R. Lon onot By: Deputy REQUESTING PARTY: Name William J. Levant, Esquire Address: 910 Harvest Drive PO Box 3037 Blue Bell, PA 19422-0765 Attorney for: Plaintiffs Telephone: 610-260-6000 Supreme Court ID No. 54286