Loading...
HomeMy WebLinkAbout14-0003 A-1 -2 Am11 PEN?4SYLVAIIIA ALEX R. SZELES, INC., ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION - LAW SIMON ELLBERGER and YIDIZ ) ELLBERGER, Husband and Wife, ) NO,?Ol q - 0003 Defendants CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of attorney, the original and a copy of which is attached to the Complaint filed in this action, I appear for the Defendants and confess judgment in the favor of the Plaintiff and against the Defendants as follows: Principal $20 Interest $11,089.42 Attorney's Commission (6 %) _ $1.212.54 Total $32 Samuel L. Andes Supreme Court ID # 17225 525 North 12' Street P.O. BOX 168 p Lemoyne, PA 17043' (717) 761 -5361 C# of 73 S e. t tP i H0 I�t A Ail I I: p$.� CU1M6E R LAi40 CC!i11 T Y PELNNS�LVANIA ALEX R. SZELES, INC., ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION - LAW SIMON ELLBERGER and YIDIZ ) ELLBERGER, Husband and Wife, ) NO. 0003 Defendants COMPLAINT FOR CONFESSION OF JUDGMENT AND NOW comes the above -named Plaintiff by its attorney Samuel L. Andes, and makes the following Complaint for the confession of judgment against the Defendants, based upon the following: 1. The Plaintiff is Alex R. Szeles, Inc., a Pennsylvania corporation with offices at 945 East Park Drive, Suite 101, Harrisburg, Dauphin County, Pennsylvania 17111. 2. The Defendants are Simon Ellberger and Yidiz Ellberger, husband and wife, who reside at 8 Briarwood Court, Camp Hill, Hampden township, Cumberland County, Pennsylvania 17011. 3. Attached hereto, and marked as EXHIBIT A, is a Judgment Promissory Note given by the Defendants to Plaintiff in the original principal amount of $20,209.03, and bearing interest at the rate of 18% per annum. The copy attached is a true and correct reproduction of the original. 4. The Promissory Note attached hereto and marked as EXHIBIT A has not been assigned by Plaintiff. 5. Judgment is not being entered in this matter by confession against a natural person in connection with a consumer credit transaction. 6. Judgment has not been entered on the Judgment Promissory Note attached hereto and marked as EXHIBIT A in this or any other jurisdiction. 7. By the terms of the said Note, judgment may be entered without any act of default on behalf of the Defendants. 8. The amount now due under the Promissory Note, is as follows: Principal $20,209.03 Interest $11,089.42 Attorney's Commission (6 %) $1,212.54 Total $32,510.99 WHEREFORE, Plaintiff demands that judgment be entered against the Defendants in the amount of $32,510.99, together with costs and interest at the rate of 18% per annum, from and after the date of entry of said judgment. Sam L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12`' Street P.O. Box 168 Lemoyne, PA 17043 (717) 761 -5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unworn falsification to authorities). ALEX R. SZELES, INC., by i Date: iz111`aQi.3 i i ������� JUDGMENT PROMISSORY NOTE $20,209.03 20 Y,2_ ON DEMAND AFTER DATE, SIMON ELLBERGER and YILDIZ ELLBERGER, the undersigned, promises to p ay to the order of ALEX R. SZELES, INC., the sum of Twenty Thousand Two Hundred and Nine ($20,209.03) DOLLARS 03/100, without offset, for value received, together with interest at the rate of eighteen (18 %) percentum per annum. This Note shall be recorded against the undersigned. The undersigned shall make regular monthly payments of Five Hundred ($500.00) Dollars, which payments will be applied first to interest then due and any balance to principal. The payments will commence on the first day of the month following the date of this Note and continue thereafter on the first day of each consecutive month until the full balance, with interest, has been paid. The failure to make any of those payments as due will be a default of this obligation and entitle the holder of the Note to all remedies allowed by law. AND FURTHER, the undersigned do hereby authorize and empower any attorney of any court of record of Pennsylvania or elsewhere to appear for the undersigned and to enter judgment against the undersigned in favor of any holder of this Note for the above sum, together with interest then due, and together with costs of suit, release of errors, and together with an attorney's commission of six (6 %) percent, and without stay of execution of any kind; and the undersigned hereby waives and releases any and all benefit and relief from any and all apprais emen t, stay or exemption laws of any state now in force or hereinafter to be passed. SIMON ELLBERGER 8 Briarwood Court Camp Hill, PA 17011 YIL A i Z LBERGIIR 8 Briarwood Court Camp Hill, PA 17011 DISCLOSURE STATEMENT The undersigned, having read this document in its entirety, and fully understanding it, hereby states, admits, acknowledges, and certifies the following: 1. I have, this day, signed a Judgment Promissory Note in which I promise to pay to ALEX R. SZELES, INC., the sum of Twenty Thousand Two Hundred and Nine 03/100 ($26,209.03) DOLLARS. 2. The said judgment note gives the persons who hold or own the note the right to file and enter judgment against me without any prior notice to me and without any right of formal pleading, notice, or hearing for me before the entry of said judgment. 3. Such a judgment entered against me will automatically create alien on all real estate owned by me at that time, whether I own it now or acquire it later. 4. Such a judgment entered against me will entitle the person who owns or holds such a judgment to issue execution against my property which can result in the Sheriff physically attaching or taking possession of said property and selling it at a Sheriff's sale. 5. That I w ill be comp elled and required to hire an attorney to file formal do cuments to open or strike such a judgment if I have a valid defense to the action taken against me, and without those documents being filed, I will not have a right to a hearing or trial on such judgment matter. 6. That I have an income, either myself or together with any other persons who signed the note with me, which is at least $10,000:00 per year. Date: 11 l i d 20 SIMON ELLBERGER 8 Briarwood Court Camp Hill, PA 17011 YILb1z 8 Briarwood Court Camp Hill, PA 17011