HomeMy WebLinkAbout05-0783
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SMIGEL, ANDERSON & SACKS, L.L.P.
River Chase Office Center
4431 North Front Street. 3" Floor
Harrisburg. PA 17110-1778
(717) 234-2401
Peter M. Good, Esquire
pgood@sasllp.com
Susan M. Zeamer, Esquire
szeamer(fi)sasllo.com
Attorneys for Petitioner
COMMERCE
BANK/HARRISBURG N.A.,
Petitioner,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
DOCKET NO. 0[;-)[>3 C;{.),{'-T<titVj
GETTY ACCOUNTING
SERVICES, INC.,
Respondent.
CIVIL ACTION - LAW
PETITION FOR INVOLUNTARY TRANSFER
OF TITLE AND OWNERSHIP OF VEHICLE
AND NOW COMES Commerce Bank/Harrisburg N.A., by and through its
attorneys, Smigel, Anderson & Sacks, L.L.P., and files the within Petition for
Involuntary Transfer of Title and Ownership of Vehicle as follows:
1. Petitioner Commerce Bank/Harrisburg N.A. ("Commerce") is a
Pennsylvania Miscellaneous Corporation with a principal place of business
located at 100 Senate Avenue, Camp Hill, Cumberland County, Pennsylvania.
2. Respondent Getty Accounting Services, Inc. ("Getty") is a
Pennsylvania business corporation with a principal place of business located at
13 Lilac Drive, Mechanicsburg, Cumberland County, Pennsylvania.
3. On or about June 10, 2003, Getty, through Keith M. Getty as
President, Vice President, Secretary, and Treasurer of Getty, entered into a
Business Loan Agreement for Loan Number 3053288 ("Agreement") in the
amount of $25,140.00 with Commerce. See Agreement, a true and correct copy
of which is attached hereto and made part of this document as Exhibit "A".
4. The Specific Loan Purpose of the Agreement was for the purchase
of a 2002 Lexus ES 300 Sedan with a Vehicle Identification Number of
JTHBF30G420016631 ("Lexus"). See Boarding Data Sheet, a true and correct
copy of which is attached hereto and made part of this document as Exhibit "B".
The Lexus served as collateral to the Agreement. See Exhibit B; see
Commercial Security Agreement, a true and correct copy of which is attached
hereto and made part of this document as Exhibit "C".
5. Under the terms of the Agreement, Getty was to make a total of
sixty (60) payments, each in the amount of $490.08, beginning July 10, 2003 and
continuing on a monthly basis thereafter. See Exhibit B.
6. Contrary to the terms of the Agreement, Getty failed to make its
October 10, 2004 payment and has failed to make any payment thereafter.
7. Although Commerce gave notice to Getty of its breach of the
Agreement and has made repeated demands for payment, Getty has failed and
refused to make such payment. See Commerce Correspondence of November
23, 2004, a true and correct copy of which is attached hereto and made part of
this document as Exhibit "D".
8. It is believed and therefore averred that there are no other lien
holders for the Lexus.
9. As Commerce is owed at least $2,450.40 in delinquent payments
toward the Agreement as well as at least $490.00 in late fees, and as the Lexus
2
'11
serves as the collateral for the Agreement, Commerce seeks to have the
ownership of the Lexus involuntarily transferred into its name for purposes of
resale to satisfy the outstanding loan balance of $19,616.40 plus the fees as set
forth herein.
WHEREFORE, Commerce Bank/Harrisburg NA prays that this
Honorable Court grant its Petition and Order that title and ownership of the 2002
Lexus ES 300 Sedan, Vehicle Identification Number JTHBF30G420016631 be
involuntarily transferred to Commerce Bank/Harrisburg N.A.
SMIGEL, ANDERSON & SACKS, L.L.P.
Date: )..1 "I of
""'- ~.
Peter M. Goo, squire
Atty. I.D. # 643
Susan M. Zeamer, Esquire
Atty. I.D. # 82023
4431 North Front Street
Harrisburg, PA 17110-1260
(717) 234-2401
Attorneys for Petitioner
Commerce Bank/Harrisburg N.A.
3
rEB-08-2005 17:43
COMMERCE LOAN CT
717 972 2867 P.03
VERIFICATION
I, Angela Masser, verify that the statements contained in the foregoing
Petition for Involuntary Transfer of Title and Ownership of Vehicle are true and
correct to the best of my knowledge, information and belief. I understand that
false statements therein are made subject to the penalties of 18 Pa.C.S. 94904,
relating to unsworn falsification to authorities.
Date: 1-{8{O'S
JSINESS LOAN AGREEME.
Principal
$25 140.00
l;oan Date
06-10-2003
Maturity
06-16-2008
References in the shaded area are for Lender's use only and do not limit the applicabmty of this document to any particular loan or item,
Any item above containing "*h" has been omitted due to text length limitations.
Borrower: Getty Accounting Services, Inc. (TIN: 23-2930197)
426 S. 3rd Street, suite #103
Lemoyne, P A
l;ender:
COMMERCE BANK/HARRISBURG N.A.
100 SENATE AVENUE
P.O. BOX 8599
CAMP HILL, PA 17011
(717) 975-5630
THIS BUSINESS LOAN AGREEMENT dated June 10,2003, is made and executed between Getty Accounting Services, Inc. ("Borrower") and
COMMERCE BANKlHARRISBURG N.A. ("Lender") on the foUowing terms and conditions. Borrower has received prior commercial loans from
Lender or has applied to Lender for a commercial loan or loans or other financial accommodations, including those which may be described
on any exhibit or schedule attached to this Agreement ("Loan"). Borrower understands and agrees that: (A) in granting, renewing, or
extending any loan, lender is relying upon Borrower's representations, warranties, and agreements as set forth in this Agreement; (B) the
granting, renewing, or extending of any loan by lender at all times shall be sUbject to lender's sole judgment and discretion; and (C) all
such l..oans shall be and remain subject to the terms and conditions of this Agreement.
TERM. This Agreement shall be effective as of June 10, 2003, and shall continue in full force and effect untll such time as all of Borrower's loans in
lavor of Lender have been paid in full, including principal, interest, costs, expenses, attorneys' fees, and other fees and charges, or until such time as
the parties may agree in writing to terminate this Agreement.
CONDITIONS PRECEDENT TO EACH ADVANCE. Lender's obligation to make the initial Advance and each subsequent Advance under this
Agreement shalf be subject to the fulfillment to Lender's satisfaction of all of the conditions set forth in this Agreement and in the Related Documents.
Loan Documents. Borrower shall provide to Lender the following documents for the Loan: (1) the Note; (2) Security Agreements granting to
Lender security interests in the Collateral; (3) financing statements and all other documents pertecting Lender's Security Interests; (4) evidence
of insurance as required below; (5) guaranties; (6) together with all such Related Documents as Lender may require for the Loan; aU in form and
substance satisfactory to Lender and Lender's counsel.
Borrower's Authorization. Borrower shalf have provided in form and substance satisfactory to Lender properly certified resolutions, duly
authorizing the' execution and delivery of this Agreement, the Note and the Related Documents. In addition, Borrower shall have provided such
other resolutions, authorizations, documents and instruments as Lender or its counsel, may require.
Payment of Fees and Expenses. Borrower shall have paid to Lender aU fees, charges, and other expenses which a.re then due and payable as
specified in this Agreement or any Related Document.
Representations and Warranties. The representations and warranties set 10rth in this Agreement, in the Related Documents, and in any
document or certificate delivered to Lender under this Agreement are true and correct.
No Event of Default. There shall not exist at the time 01 any Advance a condition which would constitute an Event of Default under this
Agreement or under any Related Document.
REPRESENTATIONS AND WARRANTIES. Borrower represents and warrants to Lender, as of the date of this Agreement, as of the date of each
disbursement of loan proceeds, as of the date of any renewal, extension or modification of any Loan, and at all times any Indebtedness exists:
Organization. Borrower is a corporation for profit which is, and at aff times shaff be, duly organized, validly existing, and in good standing under
and by virtue of the laws of the Commonwealth of Pennsylvania. Borrower is duly authorized to transact business in all other states in which
Borrower is doing business, having obtained all necessar; filings, governmental licenses and approvals for each state in which Borrower is doing
business. Specifically, Borrower is, and at all times shaff be, duly qualified as a foreign corporation in all states in which the failure to so qualify
would have a material adverse effect on its business or financial condition. Borrower has. the full power and authority to own its properties and to
transact the business in which it is presently engaged or presently proposes to engage. Borrower maintains an office at 426 S. 3rd Street, suite
#103, Lemoyne, PA. Unless Borrower has designated otherwise in writing, the principal office is the office at which Borrower keeps its books and
records including its records concerning the Collateral. Borrower will notify Lender prior to any change in the location of Borrower's state of
organization or any change in Borrower's name. Borrower shaff do aff things necessary to preserve and to keep in fuff force and effect its
existence, rights and privileges, and shalt comply with all regulations, rules, ordinances, statutes, orders and decrees of any governmental or
quasi-governmental authority or court applicable to Borrower and Borrower's business activities.
Assumed Business Names. BorrCNVer has tiled or recorded all documents or filings required by law relating to all assumed business names used
by Borrower. Excluding the name of Borrower, the following is a complete list of all assumed business names under which Borrower does
business: None.
Authorization. Borrower's execution, delivery, and performance of this Agreement and all the Related Documents have been duly authorized by
all necessary action by Borrower and do not con11ict with, result in a violation at, or constitute a default under (1) any provision of Borrower's
articles of incorporation or organization, or bylaws, or any agreement or other instrument binding upon Borrower or (2) any law, governmental
regulation, court decree, or order applicable to Borrower or to Borrower's properties.
Financial Information. Each of Borrower's financial statements supplied to Lender truly and completely disclosed Borrower's financial condition
as of the date of the statement, and there has been no material adverse change in 80rrower's financial condition subsequent to the date of the
most recent financial statement supplied to Lender. Borrower has no material contingent obligations except as disclosed in such financial
statements.
Legal Effect. This Agreement constitutes, and any instrument or agreement Borrower is required to give under this Agreement when delivered will
constitute legal, valid, and binding obligations of Borrower enforceable a.gainst Borrower in accordance with their respective terms.
Properties. Except as contemplated by this Agreement or as previously disclosed in Borrower's fina.ncial statements or in writing to Lender and as
accepted by Lender, and except for property tax liens for taxes not presently due and payable, Borrower owns and has good tille to all of
80rrower's properties free and clear of all Security Interests, and has not executed any security documents or financing statements relating to such
properties. All of Borrower's properties are titled in Borrower's legal name, and Borrower has not used or filed a iinancing statement under any
other name for at least the last five (5) years.
Hazardous Substances. Except as disclosed to and acknowledged by Lender in writing, Borrower represents and warrants that: (1) During the
period of Borrower's ownership of Borrower's Collateral, there has been no use, generation, manufacture, storage, treatment, disposal, release or
threatened release of any Hazardous Substance by any person on, under, about or from any of the Collateral. (2) Borrower has no knowl8dge 01,
BUSINESS LOAN AGREEMENl
(Continued)
Page 3
income, or profits.
Per1ormance. Periorm and comply, in a timely manner, with all terms, conditions, and provisions set forth in this Agreement, in the Related
Documents, and in all other instruments and agreements between Borrower and Lender. Borrower shall notify Lender immediately in writing of
any default in connection with any agreement.
Operations. Maintain executive and management personnel with substantially the same qualifications and experience as the present executive
and management personnel; provide written notice to Lender of any change in executive and management personnel; conduct its business affairs
in a reasonable and prudent manner.
Environmental Studies. Promptly conduct and complete, at Borrower's expense, all such investigations, studies, samplings and testings as may
be requested by Lender or any governmental authority relative to any substance, or any waste or by-product of any substance defined as toxic or
a hazardous substance under applicable federal, state, or local law, rule, regulation, order or directive, at or aHeeting any properly or any facility
owned, leased or used by Borrower.
Compliance with Governmental Requirements. Comply with all laws, ordinances, and regulations, now or hereafter in effect, of all
governmental authorities applicable to the conduct of Borrower's properties, businesses and operations, and to the use or occupancy of the
Collateral, including without limitation, the Americans With D'lsabilities Act. Borrower may contest in good faith any such law, ordinance, or
regulation and withhold compliance during any proceeding, including appropriate appeals, so long as Borrower has notified Lender in writing prior
to doing so and so long as, in Lender's sole opinion, Lender's interests in the Collateral are not jeopardized, Lender may require Borrower to pOSI
adequate security or a surety bond, reasonably satisfactory to Lender, to protect Lender's interest.
InspectiOn. Permit employees or agents of Lender at any reasonable lime to inspect any and all Collateral for tne Loan or Loans and Borrower's
other properties and to examine or audit Borrower's books, accounts, and records and to make copies and memoranda of Borrower's books,
accounts, and records. If Borrower now or at any time hereafter malntains any records (including without limitation computer generated records
and computer software programs for the generation of such records) in the possession of a third party, Borrower, upon request of Lender, shall
notify such party to permit Lender free access to such records at all reasonable times and to provide Lender with copies of any records it may
request, all at Borrower's expense.
Environmental Compliance and Reports. Borrower shall comply in all respects with any and all Environmental Laws; not cause or permit to
exist, as a result of an intentional or unintentional action or omission on Borrower's part or on the part of any third party, on property owned andlor
occupied by Borrower, any environmental activity where damage may result to the environment, unless such environmental activity is pursuant to
and in compliance with tne conditJons of a permit issued by the appropriate federal, state or local governmental authorities; shall furnish to Lender
promptly and)n any event within thirty (30) days after receipt thereof a copy of any notice, summons, lien, citation, directive, letter or other
communicati<iri. from any govemmental agency or instrumentality concerning any intentional or unintentional action or omission on Borrower's part
in connection"With any environmental activity whether or not there is damage to the environment and/or other natural resources,
Additional Assurances. Make, eXecute and deliver 10 Lender such promissory notes, mortgages, deeds of trust, security agreements,
assignments"financing statements, instruments, documents and other agreements as Lender or its attorneys may reasonably request to evidence
and secure the Loans and to perfect aU Security Interests.
LENDER'S EXPENDITURES. If any action or proceeding is commenced that would materially affect Lender's interest in the Collateral or if Borrower
fails to comply witil}3,ny pro\Jision of this Agreement or any Related Documents, includ'lng but not limited to Borrower's failure to discharge or pay when
due any amounts,Borrower is required to discharge or pay under this Agreement or any Related Documents, Lender on Borrower's behalf may (but
shall not be obligated to) take any action that Lender deems appropriate, including but not limited to discharging or paying all taxes, liens, security
interests, encumbrances and other claims, at any time levied or placed on any Collateral and paying all costs for insuring, maintaining and preserving
any Collateral. All such expenditures incurred or paid by Lender for such purposes will then bear interest at the rate charged under the Note from the
date incurred or paid by Lender to the date of repayment by Borrower. All such expenses will become a part of the Indebtedness and, at Lender's
option, will (A) be payable on demand; (B) be added to the balance of the Note and be apportioned among and be payable with any installment
payments to become due during either (1) the term of any applicable insurance policy; or (2) the remaIning term of the Note; or (C) be treated as a
balloon payment which will be due and payable at the Note's maturity,
NEGATIVE COVENANTS. Borrower covenants and agrees with Lender that while this Agreement is in effect, Borrower shall not, without the prior
written consent of Lender:
Indebtedness and Liens. (1) Except for trade debt incurred in the normal course of business and indebtedness to Lender contemplated by this
Agreement, create, incur or assume indebtedness for borrowed money, including capital leases, (2) sell, transfer, mortgage, assign, pledge,
lease, grant a security interest in, or encumber any of Borrower's assets (except as anowed as Permitted Liens), or (3) sell with recourse any of
Borrower's accounts, except to Lender,
Continuity of Operations. (1) Engage in any business activities substantially different than those in which Borrower is presently engaged, (2)
cease operations, liquidate, merge, transfer, acquire or consolidate with any other entity, change its name, dissolve or transfer or sell Collateral out
of the ordinary course of business, or (3) pay any dividends on Borrower's stock (other than d'lvidends payable In its stock), provided, however
that notwithstanding the foregoing, but only so long as no Event of Default has occurred and is continuing or would result from the payment of
dividends, if Borrower is a "Subchapter S Corporation" (as defined in the Internal Revenue Gode of 1986, as amended), Borrower may pay cash
dividends on its stock to its shareholders from time to time in amounts necessary to enable the shareholders to pay income taxes and make
estimated income tax payments to satisfy their liabilities under federal and state law which arise solely from their status as Shareholders of a
Subchapter S Corporation because of their ownership of shares of Borrower's stock, or purchase or retire any of Borrower's outstanding shares or
alter or amend Borrower's capital structure,
Loans, Acquisitions and Guaranties. (1) Loan, invest in or advance money or assets to any other person, enterprise or entity, (2) purchase.
create or acquire any interest in any other enterprise or entity, or (3) incur any obligation as surety or guarantor other than in the ordinary course
of business.
Agreements. Borrower will not enter into any agreement containing any provisions which would be violated or breached by the performance 01
Borrower's obl'igations under this Agreement or in connection herewith.
CESSATION OF ADVANCES. If Lender has made any commitment to make any Loan to Borrower, whether under this Agreement or under any other
agreement, Lender shall have no obligation to make Loan Advances or to disburse Loan proceeds if: (A) Borrower or any Guarantor is in default
under the terms of this Agreement or any of the Related Documents or any other agreement that Borrower or any Guarantor has with Lender; (8)
Borrower or any Guarantor dies, becomes incompetent or becomes insolvent, files a petition in bankruptcy or similar proceedings, or is adjudged a
bankrupt; (C) there occurs a material adverse change in Borrower's financial condition, in the financial condition of any Guarantor, or in the value 01
any Collateral securing any Loan; or (0) any Guarantor seeks, claims or othel'Nlse attempts to limn, modify or revoke such Guarantor's guaranty of the
Loan or any other loan with Lender; or (E) Lender in good faith deems itself insecure, even though no Event of Default shal! have occurred,
RIGHT OF SETOFF. Tn thp l"\){tPlIt lIP.rm\tt~rl hv ~mllli{',?J.hlF! 1?J.\N \ F!llrlAr TF!SPr\JA<; R rinh'r nf ";Plnlt in ;'Ill Rnrrnwpr'c: ;'Irrnl mtc: with I pnrlpr Iwhpthpr
BUSINESS LOAN AGREEMEN-I
(Continued)
Page 5
interests in the Loan to one or more purchasers, whether related or unrelated to Lender. Lender may provide, without any limitation whatsoever,
to anyone or more purchasers, or potential purchasers, any information or knowledge Lender may have about Borrower or about any other matter
relating to the Loan, and Borrower hereby waives any rights to privacy Borrower may have with respect to such matters. Borrower additionally
waives any and all notices of sale of participation interests, as well as all notices of any repurchase of such participation interests. Borrower also
agrees that the purchasers of any such participation interests will be considered as the absolute owners of such interests in the Loan and will have
all the rights granted under the participation agreement or agreements governing the sale of such participation interests. Borrower further waives
all rights 01 offset or counterclaim that it may have now or later against Lender or against any purchaser of such a participation interest and
unconditionally agrees that either Lender or such purchaser may enforce Borrower's obligation under the Loan irrespective of the failure or
insolvency of any holder of any interest in the Loan. Borrower further agrees that the purchaser of any such participation interests may enforce its
interests irrespective of any personal claims or defenses that Borrower may have against Lender.
Governing law. This Agreement will be governed by, construed and enforced in accordance with federal law and the laws of the
Commonwealth of Pennsylvania. This Agreement has been accepted by lender in the Commonwealth of Pennsylvania.
No Waiver by lender. Lender shall not be deemed to have waived any rights under this Agreement unless such waiver is given in writing and
signed by Lender. No delay or omission on the part of Lender in exercising any right shall operate as a waiver of such right or any other right. A
waiver by lender of a provision of this Agreement shall not prejudice or constitute a waiver of Lender's right otherwise to demand strict
compliance with that provision or any other provision of this Agreement. No prior waiver by Lender, nor any course of dealing between Lender
and Borrower, or between lender and any Grantor, shall constitute a waiver of any of Lender's rights or of any of Borrower's or any Grantor's
obligations as to any future transactions. Whenever the consent of Lender is required under this Agreement the granting of such consent by
Lender in any instance shall not constitute continuing consent to subsequent instances where such consent is required and in all cases such
consent may be granted or withheld in the sole discretion of Lender.
Notices. Unless otheiWise provided by applicable law, any notice required to be given under this Agreement shall be given in writing, and shall
be effective when actually delivered, when actually received by telefacsimile (unless otherwise required by law), when deposited with a nationally
recognized overnight courier, or. if mailed, when deposited in the United States mail, as first class, certified or registered mail postage prepaid,
directed to the addresses shown near the beginning of this Agreement Any party may change its address for notices under this Agreement by
giving formal written notice to the other parties, speCifying that the purpose of the notice is to change the party's address. For notice purposes,
Borrower agrees to keep Lender informed at all times of Borrower's current address. Unless otherwise provided by applicable law, if there is more
than one Borrower, any notice given by Lender to any Borrower is deemed to be notice given to all Borrowers.
Severability. If a court of competent jurisdiction finds any provision of this Agreement to be illegal, invalid, or unenforceable as to any
circumstance,,,Jhat finding shall not make the offending provision illegal, invalid, or unenforceable as to any other circumstance. If feasible, the
offending proyision shall be considered modified so that it becomes legal, valid and enforceable. If the offending provision cannot be so modified,
it shall be considered deleted from this Agreement Unless otherwise required by law, the illegality, invalidity, or unenforceability of any provision
of this Agreement shall not affect the legality, validity or enforceability of any other provision of this Agreement.
Subsidiaries and Affiliates of Borrower. To the extent the context of any provisions of this Agreement makes it appropriate, including without
limitation any. representation, warranty or covenant, the word "Borrower" as used in this Agreement shall include all of Borrower's subsidiaries and
affiliates. Notwithstanding the foregoing however, under no circumstances shall this Agreement be construed to require Lender to make any Loan
or other finanCial accommodation to any of Borrower's subsidiaries or affiliates.
Successors ,and Assigns. All covenants and agreements by or on behalf of Borrower contained in this Agreement or any Related Documents
shall bind BorJower's successors and assigns and shall inure to the benefit of Lender and its successors and assigns. Borrower shaH not,
however, have the right to assign Borrower's rights under this Agreement or any interest therein, without the prior written consent of Lender.
Survival of Representations and Warranties. Borrower understands and agrees that in making the Loan, Lender is relying on all
representations, warranties, and covenants made by Borrower in this Agreement or in any certificate or other instrument delivered by Borrower to
Lender under this Agreement or the Related Documents. Borrower further agrees that regardless of any investigation made by Lender, aU such
representations, warranties and covenants will survive the making of the Loan and delivery to Lender of the Related Documents, shall be
continuing in nature, and shall remain in full force and effect until such time as Borrower's Indebtedness shall be paid in full, or until this
Agreement shall be terminated in the manner provided above, whichever is the last to occur.
Time is of the Essence. Time is of the essence in the performance of this Agreement.
DEFINITIONS. The following capitalized words and terms shall have the following meanings when used in this Agreement. Unless specifically stated
to the contrary, all references to dollar amounts shall mean amounts in lawful money of the United States of America. Words and terms used in the
singular shall include the plural, and the plural shall include the singular, as the context may require. Words and terms not otherwise defined in this
Agreement shall have the meanings attributed to such terms in the Uniform Commercial Code. Accounting words and terms not othe/Wise defined in
this Agreement shall have the meanings assigned to them in accordance with generally accepted accounting principles as in effect on the date of this
Agreement:
Advance. The word "Advance" means a disbursement of Loan funds made, or to be made, to Borrower or on Borrower's behalf on a line of credit
or multiple advance basis under the terms and conditions of this Agreement.
Agreement. The word "Agreement" means this Business Loan Agreement, as this Business Loan Agreement may be amended or modified from
time to time, together with all exhibits and schedules attached to this Business Loan Agreement from time to time.
Borrower. The word "Borrower" means Getty Accounting Services, Inc. and includes all co-signers and co-makers signing the Note.
CollateraL The word "Collateral" means aU property and assets granted as collateral security for a Loan, whether real or personal property,
whether granted directly or indirectly, whether granted now or in the future, and whether granted in the form of a security interest, mortgage,
collateral mortgage, deed of trust, assignment, pledge, crop pledge, chattel mortgage, collateral chattel mortgage, chattel trust, factor's lien,
equipment trust, conditional sale, trust receipt, lien, charge, lien or title retention contract, lease or consignment intended as a security device, or
any other security or lien interest whatsoever, whether created by law, contract, or otherwise.
Environmental Laws. The words "Environmental Laws" mean any and all state, federal and local statutes, regulations and ordinances relating to
the protection of human health or the environment, including without limitation the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended, 42 U.S.C. Section 9601, et seq. ("CERCLA"), the Superfund Amendments and Reauthorization Act of 1986, Pub.
L. No. 99-499 ("SARA"), the Hazardous Materials Transportation Act, 49 U.S.C. Section 1801, et seq., the Resource Conservation and Recovery
Act, 42 U.S.C. Section 6901, et seq., or other applicable state or federal laws, rules, or regulations adopted pursuant thereto.
Event of Default. The words "Event of Default" mean any of the events of default set forth in this Agreement in the default section of this
Agreement.
GAAP. The word "GAAP" means generally accepted accounting principles.
BOARDING DATA SHEET
Principal Loan Date Maturity
$25,140.00 06-10-2003 06-10-2008
References in the shaded area are for Lender's use only and do not limit the applicability 01 this document to any particular loan or item.
Any item above containing ..~.,,' has been omitted due to text length limitations.
Borrower: Getty Accounting Services, Inc. (TIN: 23-2930197)
426 S. 3rd Street, suite #103
Lemoyne, PA
Lender:
COMMERCE BANK/HARRISBURG N.A.
100 SENATE AVENUE
P.O. BOX 8599
CAMP Hill, PA 17011
(717) 975-5630
Getty Accounting Services, Inc.
Street Address; 426 S. 3rd Street, suite #103
Mailing Address:
Resolution: New Resolution
23-2930197
Lemoyne
Corporation
PA
Borrower
County: Cumbenand
County:
Officer of Getty Accounting Services, Inc.:
Keith M. Getty
Street Address: 136 N. 33rd Street
198-62-8710 Individual Officer
lemoyne PA 17043 County: Cumberland
198-62-8710 Individual Guarantor
Guaranty Amount Unlimited
Lemoyne PA 17043 County: Cumberland
186-62-5022 Individual Guarantor
Guaranty Amount: Unlimited
Lemoyne PA 17043 County: Cumberland
Keith M. Getty
Street Address; 136 N. 33rd Street
Cheryl S. Getty
Street Address: 136 N. 33rd Street
Transaction No.: 7602
Product Category: 2
Loan Policy: Commercial
Cust #:
Phone:
NAICS: 541214
Title: PresN.Presrrrea/Sec
Cust #:
Phone:
Cust#'
Phone:
Cust #:
Phone:
Product Description: COMMERCIAL
Purpose: Loan is not for Personal, Family, Household Purposes or Personal Investment Purposes.
Specific Loan Purpose: Financing the purchase of a 2002 lexus ES 300.
Application No:
Application Date:
loan No: 3053288
loan Date: D6.1(}.2oo3
Officer: 145 Ceriani, Karen
Processor No: JCR Romanak, Joe
Collateral Code:
Charge Code:
Call Code:
User Code 3:
User Code 6:
Automatic Payments:
Branch:
Dept Loan Documentation
Division:
Region:
Loan Type: Installment (Direct -Installment)
Loan Class: New loan
Purpose Code:
Class Code:
User Code 1:
User Code 4:
User Code 7:
Employee Loan: No
Restricted Access: No
Reg 0 loan: No
Comments:
Portfolio Code:
Host System:
User Gode 2:
User Gode 5:
User Code 8:
T e
Titled
Owner(s):
SubT e
Motor Vehicle
Descrf tion
2002 Lexus ES 300 Sedan (VIN JTHBF30G420016631)
PA
Getty Accounting Services, Inc.
Street Address: 426 S. 3rd Street, suite #103
Mailing Address:
Resolution: New Resolution
23-2930197
Lemoyne
Corporation
PA
County: Cumberland
County:
Officer of Getty Accounting Services, Inc.:
Keith M. Getty
Street Address: 136 N. 33rd Street
198M62M8710 Individual
lemoyne PA 17043
Officer
County: Cumberland
$31,423.00
y
Gust #:
Phone:
NAICS 541214
Title: PresN.PreslTrealSec
Cust #:
Phone:
COI'vll~ERCIAL SECURITY AGREb~ENT
j'.I,.Bfln;B~.t~(.
:;O&~1i:H?QOa
References in the shaded area are for Lender's use only and do not limit the applicability of this document to any partIcular loan or item.
Any item above containing ,,~u" has been omitted due to text length limitatIons.
.. Mllturlty ..
()&.10-2oo8
Grantor:
Getty Accounting Services, Inc. (TIN: 23-2930197)
426 S. 3rd Street, suite #103
Lemoyne, P A
Lender:
COMMERCE BANKlHARRISBURG N.A.
100 SENATE AVENUE
P.O. BOX 6699
CAMP Hill, PA 17011
(717) 975.5630
THIS COMMERCiAL SECURITY AGREEMENT dated June 10, 2003, is made and executed between Getty Accounting Services, Inc. ("Grantor")
and COMMERCE BANK/HARRISBURG N.A. ("lender").
GRANT OF SECURITY INTEREST. For valuable consideration, Grantor grants to Lender a security interest in the Collateral to secure the
Indebtedness and agrees that Lender shall have the rights stated in this Agreement with respect to the Collateral, in addition to al/ other rights
which Lender may have by law.
COLLATERAL DESCRIPTION. The word "Collateral" as used in this Agreement means the fOllowing described property in which Grantor is giving to
lender a security interest for the payment of the Indebtedness and performance of all other obligations under the Note and this Agreement
2002 lexus ES 300 Sedan (VIN JTHBF30G420016631)
In addition, the word "Collateral" also includes all the following:
(A) All accessions, attachments, accessories, replacements of and additions to any of the collateral described herein, whether added now or later.
(B) All products and produce of any of the property described in this Collateral section.
{C} All accounts, general intangibles, instruments, rents, monies, payments, and all other rights, arising out of a sale, lease, or other disposition of
any of the property described in this Collateral section.
(D) All proceeds (including insurance proceeds) from the sale, destruction, loss, or other disposition of any of the property described in this
Collateral section, and sums due from a third party who has damaged or destroyed the Collateral or from that party's insurer, whether due to
judgment, settlement or other process.
(E) All records and data relating to any of the property described in this Collateral section, whether in the form of a writing, photograph, microfilm,
microfiche, or electronic media, together with aU of Grantor's right, title, and interest in and to aU computer software required to utilize, create,
maintain, and process any such records or data on electronic media.
Despite any other provision of this Agreement, Lender is not granted, and will not have, a nonpurchase money security interest in household goods, to
the extent such a security interest would be prohibited by applicable law. In addition, if because of the type of any Property, lender is required to give
a notice of the right to cancel under Truth in Lending for the Indebtedness, then Lender wilt not have a security interest in such Collateral unless and
until such a notice is given.
RIGHT OF SETOFF. To the extent permitted by applicable law, Lender reserves a right of setoff in an Grantor's accounts with Lender (whether
checking, savings, or some other account). This includes aU accounts Grantor holds jointly with someone else and all accounts Grantor 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. Grantor
authorizes Lender, to the extent permitted by applicable law, to charge or setoH al\ sums owing on the Indebtedness against any and aU such accounts.
GRANTOR'S REPRESENTATIONS AND WARRANTIES WITH RESPECT TO THE COllATERAL. With respect to the Collateral, Grantor represents
and promises to Lender that:
Perfection of Security Interest. Grantor agrees to execute financing statements and to take whatever other actions are requested by Lender to
perfect and continue Lender's security interest in the Collateral. Upon request of Lender, Grantor will deliver to Lender any and all of the
documents evidencing or constituting the Collateral, and Grantor will note Lender's interest upon any and all chattel paper if not delivered to
Lender for possession by Lender.
Notices to Lender. Grantor will promptly notify Lender in writing at lender's address shown above (or such other addresses as lender may
designate from time to time) prior to any (1) change in Grantor's name; (2) change in Grantor's assumed business name(s); (3) change in the
management of the Corporation Grantor; (4) change in the authorized signer(s); (5) change in Grantor's principal office address; (6) change in
Grantor's state of organization; (7) conversion of Grantor to a new or different type of business entity; or (8) change in any other aspect of
Grantor that directly or indirectly relates to any agreements between Grantor and lender. No change in Grantor's name or state of organization
will take eHect until after Lender has received notice
No Violation. The execution and delivety of this Agreement will not violate any law or agreement governing Grantor or to which Grantor is a party,
and its certificate or articles of incorporation and bylaws do not prohibit any term or condition of this Agreement.
Enforceability of Collateral. To the extent the Collateral consists of accounts, chattel paper, or general intangibles, as defined by the Uniform
Commercial Code, the Collateral is enforceable in accordance with its terms, is genuine, and fully complies with all applicable laws and regulations
concerning form, content and manner of preparation and execution, and all persons appearing to be obligated on the Collateral have authority
and capacity to contract and are in fact obHgated as they appear to be on the COllateral. there shaU be no setoffs or counterclaims against any or
the Collateral, and no agreement shall have been made under which any deductions or discounts may be claimed concerning the Ca\1ateral
except those disclosed to Lender in Wilting.
location of the Collateral. Except for vehicles, and except otherwise in the ordinary course of Grantor's business, Grantor agrees to keep the
Collateral at Grantor's address shown above or at such other locations as are acceptable to Lender. If the CoHateralis a vehicle, Grantor will keep
the Collateral at those addresses except for routine travel. Upon Lender's request, Grantor will deliver to Lender in form satisfactory to lender a
schedule of real properties and Collateral locations relating to Grantor's operations, including without limitation the following: (1) all real property
Grantor owns or is purchasing; (2) ail real property Grantor is renting or teasing; (3) all storage facilities Grantor owns, rents, leases, or uses;
and (4) alt other properties where Collateral is or may be located.
Removal of the Collateral. Except in the ordinary course of Grantor's business, Grantor shaH not remove the Collateral from its existing location
without Lender's prior written consent. To the extent that the Collateral consists of vehicles, or other titled property, Grantor shaJJ not take or permit
any action which would requrre application for certificates of title for the vehicles outside the Commonwealth ot Pennsylvania, without Lender's
",r;""r ",.;1+...,., ,",,,...,,,,,,,,,.,. ~~"'n.,",~ o:-h",11 ",h",nco""'~ ~o,..,"oc.c.,,"-l "'rh,;<,,,, I n,..,rl,.,~,..,f ih" "".,..... I....,~'>.;....,..,....I .....,.... r-,..,II................
CuMMERCIAL SECURITY AGREEfvlc.NT
(Continued)
Page 3
prohibited by law or unless Lender is required by law to pay such fees and costs. Grantor irrevocably appoints Lender to execute flnancing
statements and documents of title in Grantor's name and to execute aU documents necessary to transfer title if there is a default. Lender may file a
copy of this Agreement as a financing statement. If Grantor changes Grantor's name or address, or the name or address of any person granting a
security interest under this Agreement changes, Grantor will promptly notify the lender of such change.
GRANTOR'S RIGHT TO POSSESSION. Until default, Grantor may have possession of the tang[bte personal property and beneficial use of all the
CoUateral and may use it in any lawful manner not inconsistent with this Agreement or the Related Documents, provided that Grantor's right to
possession and beneficial use shall not apply to any Collateral where possession at the CaUateral by Lender is required by law to perfect Lender's
security interest in such CollateraL If Lender at any time has possession ot any Collateral, whether before or after an Event of Default, lender shall be
deemed to have exercised reasonable care in the custody and preservation of the Collateral if Lender takes such action for that purpose as Grantor
shall request or as Lender, in Lender's sole discretion, shall deem appropriate under the circumstances, but failure to honor any request by Grantor
shall not of itself be deemed to be a faJJure to exercise reasonable care. Lender shall not be required to take any steps necessary to preserve any rights
in the Collateral against prior parties, nor to protect, preserve or maintain any security interest given to secure the lndebtedness_
LENDER'S EXPENDITURES. If any action or proceeding is commenced that would materially affect Lender's interest in the Collateral or if Grantor fails
to comply with any provision of this Agreement or any Related Documents, including but not fimited to Grantor's failure to discharge or pay when due
any amounts Grantor is required to discharge or pay under this Agreement or any Related Documents, Lender on Grantor's behalf may (but shatll10t be
obligated to) take any action that Lender deems appropriate, induding but not limited to discharging or paying all taxes, liens, security interests,
encumbrances and other claims, at any t[me levied or placed on the Collateral and paying all costs lor insuring, maintaining and preserving the
Collateral. All such expenditures incurred or paid by Lender for such purposes will then bear interest at the rate charged under the Note from the date
incurred or paid by Lender to the date of repayment by Grantor. All such expenses will become a part of the Indebtedness and, at Lender's option, will
(A) be payable on demand; (B) be added to the balance of the Note and be apportioned among and be payable with any installment payments to
become due during either (1) the term of any applicable insurance polley; or (2) the remaining term of the Note; or (e) be treated as a balloon
payment Which will be due and payable at the Note's maturity. The Agreement also will secure payment of these amounts. Such right shaH be in
addition to all other rights and remedies to which Lender may be entltled upon Default.
DEFAULT. Each of the following shall constitute an Event of Default under this Agreement:
Payment Default. Grantor fails to make any payment when due under the Indebtedness.
Other Defaults. Grantor fails to comply with or to perform any other term, obligation, covenant or condition contained in this Agreement 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 between
Lender and G~antor.
d
Default in Fa)lor of Third Parties. Should Borrower or any Grantor default 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 attect any of Grantor's property or Granlor's
or any Grantor~s ability to repay the Indebtedness or perform their respective obligations under this Agreement or any of the Related Documents.
False Statements. Any warranty, representation or statement made or furnished to Lender by Grantor or on Grantor's behalf under this
Agreement 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.
Defective C6Jlateralization. This Agreement or any of the Related Documents ceases to be in full lorce and effect (inctuding failure of any
coUatera~ document to create a valid and perfected security interest or lien) at any time and for any reason.
Insolvency. .,The dissolution or termination of Grantor's existence as a going business, the insolvency of Grantor, the appointment of a receiver for
any part of Grantor's property, any assignment for the benefit of creditors, any type 01 creditor workout, or the commencement of any proceeding
under any bankruptcy or insolvency laws by or against Grantor.
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 Grantor Dr by any governmental agency against any collateral securing the Indebtedness.
This includes a garnishment of any of Grantor's accounts, including deposit accounts, with Lender. However, this Evenl ot Default shall not apply
if there is a good faith dispute by Grantor as to the validity or reasonableness of the claim which is the basis ot the creditor or forfeiture proceeding
and if Grantor gives Lender written notice of the crectilor or forteiture 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 Dr bond lor the dispute.
Events Affecting Guarantor. Any of the preceding events occurs with respect to Guarantor of any of the Indebtedness or Guarantor dies or
becomes incompetent or revokes or disputes the validity of, or liability under, any Guaranty of the Indebtedness.
Adverse Change. A material adverse change occurs in Grantor's financial condition, or Lender believes the prospect of payment or performance
of the Indebtedness is impaired.
Insecurity. Lender in good faith believes itself insecure.
Cure Provisions. If any default, other than a default in payment is curable and if Grantor has not been given a notice of a breach of the same
provision of this Agreement Within the preceding twelve (12) months, it may be cured (and no event of default will have occurred) if Grantor, after
receiving written notice from Lender demanding cure of such default: (1) cures the default within fifteen (15) days; or (2) if the cure requires
more than 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.
RIGHTS AND REMEDIES ON DEFAULT. If an Event of Default occurs under this Agreement, at any time thereafter, Lender shall have all the rights of
a secured party under the Pennsylvania Uniform Commercia! Code. In addition and without limitation, Lender may exercise anyone or more of the
fOllOWing rights and remec:lies:
Accelerate Indebtedness. Lender may declare the entire Indebtedness, including any prepayment penalty which Grantor would be required to
pay, immediately due and payable, without notice of any kind 10 Grantor.
Assemble Collateral. Lender may require Grantor to deliver to Lender all or any portion of the Collateral and any and all certificates of tiUe and
other documents relating to the Collateral. Lender may require Grantor to assemble the Collateral and make it available to Lender at a place to be
designated by Lender. lender also shall have full power to enter upon the property of Granter to take possession at and remove the Collateral. If
Ine ~ollateral contains other goods not covered by this Agreement at the time of repossession, Grantor agrees Lender may take such other goods,
prOVided that Lender makes reasonable efforts to return them to Grantor after repossession.
Sell the Collateral. lender shall have full power to sell, lease, transfer, or otherwise deal with the Co))ateraJ or proceeds thereof in Lender's own
name or. that of Grantor. Le~der may sell the C.oUateral at public auc~ion. or private sale. Unless the Collateral threatens to decline speedily in
value or \s of a type customanly sold on a recognlzed market, Lender will give Grantor, and other persons as required by law, reasonable notice of
In"" timp ~mrl n\;:1('.p nf ::Jnv nllhtir. SellA nr thA timp. i'lft;::,r whir:h Clnv mivCJ.tA s<'Ilp. nr ;lnV (JthAr rli,c;nnc;itinn nf \hn f":r,n",t...r",1 i", In he. ',"",:>rie. W"",,,,,,Cl' n"
CullJ1MERCIAL SECURITY AGREEIIi,_,'-lT
(Continued)
Page 5
it shall be considered deleted from this Agreement. Unless otherwise required by law, the illegality, invalidity, or un enforceability of any provision
01 this Agreement shall not atlect the legality, validity or 81'110rCeabi\\ty 01 any other prov'lsion of Ih'ls Agreement.
Successor Interests. The terms of this Agreement shall be binding upon Grantor, and upon Grantor's heirs, personal representatives,
successors, and assigns, and snaIl be enforceable by Lender and its successors and assigns.
Survival of Representations and Warranties. All representations, warranties, and agreements made by Grantor in this Agreement shan sUNive
Ihe execution and delivery of this Agreement, shall be continuing in nature, and shall remain in full force and effect until such time as Grantor's
Indebtedness shall be paid in fulL
Time is of the Essence. Time is of the essence in the performance of this Agreement.
DEFINITIONS. The following capitalized words and terms shall have the foHowing meanings when used \n this Agreement Unless specifically stated
to the contrary, all references to dollar amounts shall mean amounts in lawful money 01 the Unlted States of America. Words and. terms used in the
singular shall include the plural, and the plural shall. include the singular, as the context may require. Words and terms not otherN\~,e delined in this
Agreement shall have the meanings attributed to such terms in the Uniform Commercial Code:
Agreement. The word "Agreement" means this Commercial Security Agreement, as this Commerc.\al Security Agreement may be amended or
modified from time to time, together with all exhibits and schedules attached to this Commercial Security Agreement from time to time
Borrower. The word "Borrower" means Getty Accounting Services, Inc. and includes all co-s'lgners and co-makers signing the Note.
Collateral. The word "Collateral" means all of Grantor's right, title and interest in and to all the Collateral as described in the Collateral Description
section of this Agreement.
Default. The word "Default" means the Default set forth in this Agreement in the section titled "Default".
Environmental Laws. The words "Environmental Laws" mean any and all state, federal and local statutes, regulations and ordinances relating to
the protection of human health or the environment, including without limitation the Comprehensive Envimnmental Response, Compensation, and
Liability Act of 1980, as amended, 42 U.S.C. Section 9601, et seq. ("CERCLA"), the Superfund Amendments and Reauthorization Act of 1986, Pub.
L. No. 99.499 ("SARA"), the Hazardous Materials Transportation Act, 49 U.S.C. Section 1801, et seq., the Resource Conservation and Recovery
Act, 42 U.S.C. Section 6901, et seq., or other applicable state or federal laws, rules, or regulations adopted pursuant thereto.
Event of Default. The words "Event of Default" mean any of the events of default set forth in this Agreement in the detault section of this
Agreement.
Grantor. Th~.word "Grantor" means Getty Accounting Services, loc..
Guarantor. 1!1e word "Guarantor" means any guarantor, surety, or accommodation party of any or all of the Indebtedness,
Guaranty. The word "Guaranty" means the guaranty from Guarantor to Lender, including without limitation a guaranty of all or part of the Note.
Hazardous Substances. The words "Hazardous Substances" mean materials. that, because 01 their quantity, COf)cen~rat\Of) or physical, chemical
or infectious characteristics, may cause or pose a present or potential hazard to human health or the environment when improperly used, treated,
stored, disposed of, generated, manufactured, transported or otherwIse handled. The words "Hazardous Substances" are used In their very
broadest sense and include without limitation any and all hazardous or toxic substances, materials or waste as defined by or listed under the
Environmental laws. The term "Hazardous Substances" also includes, without limitation, petroleum and petroleum by-products or any fraction
thereof and asbestos.
Indebtedness. The word "Indebtedness" means the indebtedness evidenced by the Note or Related Documents, including all principal and
interest together with all other indeb~edness and costs and expenses for which Grantor is responsible under this Agreement or under any of the
Related Documents. The liens and securIty interests created pursuant to this Agreement covering the Indebtedness which may be created in the
future shall relate back to the date 01 this Agreement.
Lender. The word "lender" means COMMERCE BANK/HARRISBURG N.A., its successors and assigns.
Note. The word "Note" means the Note executed by Getty Accounting Services, Inc, in the principal amount of $25,140.00 dated June 10, 2003,
together with all renewals of, extensions of, modifications of, refinancings of, consolidations of, and substitutions for the note or credit agreement.
Property. The word "Property" means all of Grantor's right, title and interest in and to aU the Property as described in the "Collateral Description"
section of thIs Agreement.
Related Documents. The words "Related Documents" mean all promissory notes, credit agreements, loan agreements, environmental
agreements, guaranties, security agreements, mortgages, deeds of trust, security deeds, collateral mortgages, and all olner Instruments,
agreements and documents, whether now or hereafter existing, executed in connection with the Indebtedness.
GRANTOR HAS READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS COMMERCIAL SECURITY AGREEMENT AND AGREES TO ITS
TERMS. THIS AGREEMENT IS DATED JUNE 10. 2003.
GRANTOR:
GETTY ACCOUNTING SERVICES, INC.
.4M /1<A
By:
Keith M. Getty, Pr N.?resrrreaiSec
Accounting Services, lnc.
of Getty
v..sBl?l'\O LooM",. ,,~, ; <2.00 oo~ Cop'. '1.".,,,, F,n.n<,., SolU11"",,_ II><. '997. 2lXJ3 ..,1 R;y"'-' Re.~,""" . PA H,'W,W,PPSlLPw'NlCFI'U'lIE..:!.FC TR.7""Z PR-'.
Commerce
"Bank
November 23, 2004
KEITH GETTY
136 NORTH 33RO STREET
CAMP HILL, PA 17011
RE: Loan Account: # 3053288
This notice will serve as formal notification that you are in default on the above
loan because the account is 43 days past due.
Commerce BanklHarrisburg, N.A. is hereby demanding payment
of the past due loan balance no later than the close of business on
12/03/2004. The amount due at this time is as follows:
10/10/2004
11110/2004
Late fees through 11/23/2004
$ 490.08
$ 490.08
$ 196.00
Total Due
$1,176.16
If the past due balance is not paid by the close of business on 12/03/2004 as
demanded herein, be advised that the Bank will pursue all legal remedies against
you as explained in your Promissory Note.
If you have any questions on this matter, please contact me at 1-888-937-0004.
Sincerely,
COMMERCE BANKIHARRISBURG, N.A.
~(/U/uL Cta~t1
Tasha Claggett
Asset Quality
Commerce Bank / Harrisburg, N.A.
P.O Box 8599
'00 Senate Avenue
Camp Hil!. Pennsylvania 17001 ~8599
Commerce
_Bank
November 23, 2004
CHERYL S. GETTY
136 NORTH 33RD STREET
CAMP HILL, PA 1701]
RE: Loan Account: # 3053288
This notice will serve as formal notification that you are in default on the above
loan because the account is 43 days past due.
Commerce Bank/Harrisburg, N.A. is hereby demanding payment
of the past due loan balance no later than the close of business on
12/03/2004. The amount due at this time is as follows:
10110/2004
] 1/10/2004
Late fees through 1] 12312004
$ 490.08
$ 490.08
$ 196.00
Total Due
$1,176.16
If the past due balance is not paid by the close of business on 12/03/2004 as
demanded herein, be advised that the Bank will pursue all legal remedies against
you as explained in your Promissory Note.
If you have any questions on this matter, please contact me at 1-888-937-0004.
Sincerely,
COMMERCE BANKIHARRISBURG, N.A.
;iaah-- Cta%ftl
Tasha Claggett
Asset Quality
Commerce Bank I Harrisburg, N,A.
P.O Box 8599
100 Senate Avenue
Camp Hill, Pennsylvania 17001-8599
COMMERCE
BANK/HARRISBURG N.A.,
Petitioner,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
DOCKET NO.
GETTY ACCOUNTING
SERVICES, INC.,
Respondent.
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Susan M. leamer, hereby certify that a copy of the foregoing Petition
for Involuntary Transfer of Vehicle Title and Ownership was served upon the
following as the party with an interest in the vehicle, by depositing a true and
correct copy in an envelope, postage prepaid and mailed by first-class and
certified mail, return receipt requested, addressed as follows:
Getty Accounting Services, Inc.
13 Lilac Drive
Mechanicsburg, PA 17050-3189
and
clo Keith Getty
19 North 24th Street
Camp Hill, PA 17011
Pro Se Respondent
SMIGEL, ANDERSON & SACKS, L.L.P.
2[91 o~
/ B' """'-~.
eter M. Go
.D. Number: 6 16
Susan M. leamer, Esquire
I.D. Number: 82023
River Chase Office Center
4431 North Front Street
Harrisburg, PA 17110-1778
(717) 234-2401
Attorneys for Petitioner
Commerce Bank/Harrisburg NA
COMMERCE
BANK/HARRISBURG N.A.,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-783 CIVIL TERM
GETTY ACCOUNTING
SERVICES, INC.,
Respondent
CIVIL ACTION - LAW
ORDER OF COURT
AND NOW, this 18th day of February, 2005, a Rule
is issued upon Respondent to show cause why the relief requested
in the "Petition for Involuntary Transfer of Title Ownership"
should not be granted. Rule returnable March 11, 2005, at 1:00
p.m. in Courtroom No. 5 of the Cumberland County Courthouse,
Carlisle, Pennsylvania.
By the Court,
Peter M. Good, Esquire
~~an M. Zeamer, Esquire
~~gel, Anderson & Sacks, L.L.P.
4431 North Front Street
Harrisburg, PA 17110-1778
Attorneys for the Petitioner
~ty Accounting Services, Inc.
13 Lilac Drive
Mechanicsburg, PA 17050-3189
)
.07
....\~
'ca-
o
and
Aith Getty
19 North 24th Street
Camp Hill, PA 17011
Respondent, Pro se
- '.-'
!'.! C i
1 ;~
~i ::
srs
1 ~"' . ,',",
" -
E.:.-
COMMERCE
BANK/HARRISBURG N.A.,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-783 CIVIL TERM
GETTY ACCOUNTING
SERVICES, INC.,
Respondent
CIVIL ACTION - LAW
ORDER OF COURT
AND NOW, this 18th day of February, 2005, a Rule
is issued upon Respondent to show cause why the relief requested
in the "Petition for Involuntary Transfer of Title Ownership"
should not be granted. Rule returnable March 11, 2005, at 1:00
p.m. in Courtroom No. 5 of the Cumberland County Courthouse,
Carlisle, Pennsylvania.
By the Court,
Peter M. Good, Esquire
~JSan M. Zeamer, Esquire
~~gel, Anderson & Sacks, L.L.P.
4431 North Front Street
Harrisburg, PA 17110-1778
Attorneys for the Petitioner
~ty Accounting Services, Inc.
13 Lilac Drive
Mechanicsburg, PA 17050-3189
)
.07
__\Cb
.l'}
(j
and
Ai th Getty
19 North 24th Street
Camp Hill, PA 17011
Respondent, Pro se
srs
"" .,'" .'!
.'.> ,.
,- ,.'.-'
COMMERCE BANK/HARRISBURG
N.A. ,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Petitioner
V.
GETTY ACCOUNTING
SERVICES, INC.,
Respondent
CIVIL ACTION - LAW
NO. 05-783 CIVIL TERM
ORDER OF COURT
AND NOW, this 11th day of March, 2005, a hearing
on the Plaintiff's Petition for Involuntary Transfer of
Title and Ownership of Vehicle is set before this Court on
Monday, April 18, 2005, at 1:00 p.m. Plaintiff is directed
to effectuate appropriate service of the petition and this
order upon Defendant at least ten days prior to said
hearing.
Edward E. Guido, J.
Richard C. Gaffney, Jr., Esquire
Smigel, Anderson & Sacks, L.L.P.
River Chase Office Center
4431 North Front Street
Harrisburg, PA 17110-1709
L r(fJIt!
(..1
. 03.!'U)S
:lfh
'j,.'.
...... \
,;j
COMMERCE
BANK/HARRISBURG N.A.,
Petitioner,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
DOCKET NO. oS; -183
GETTY ACCOUNTING
SERVICES, INC.,
Respondent.
CIVIL ACTION - LAW
ORDER
~
AND NOW, this It day of
~
, 2005, on
consideration of Commerce Bank, Harrisburg, N.A.'s Motion for Special Relief
Authorizing Service by Publication, and on finding that Commerce has made a
good faith effort to locate the defendant, it ;s hereby ORDERED that Commerce's
Motion is GRANTED. Commerce is authorized to effectuate service by
~~
publication 'Nitl.il'l_ da1~ d t1,;:; Ola!>!. ~ J JrA.M J;O (J S- c.:J-
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COMMERCE
BANK/HARRISBURG NA,
Petitioner,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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DOCKET NO. oS - 7[3
CI~,L T&.~
GETTY ACCOUNTING
SERVICES, INC.,
Respondent.
CIVIL ACTION - LAW
ORDER
AND NOW, this /JI"daYOf ~
, 2005, after
reasonable notice and an opportunity for hearing having been provided to all
interested parties, the Court hereby awards ownership of one 2002 Lexus ES
300 Sedan bearing vehicle identification number JTHBF30G420016631 to
Petitioner Commerce Bank/Harrisburg N.A., and the right, title and interest of any
other person to said vehicle is hereby extinguished. The Commonwealth of
Pennsylvania, Department of Transportation may accept this order as evidence
of ownership in lieu of a Certificate of Title. The Petitioner shall submit the
appropriate forms, taxes and fees and comply with any other procedures of the
Commonwealth of Pennsylvania, Department of Transportation in order to
receive the appropriate Certificate of Title for said vehicle.
Judge
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SMIGEL, ANDERSON & SACKS, LLP
River Chase Office Center
4431 North Front Street, 3m Floor
Harrisburg, P A 17110
Peter M. Good, Esquire
mwod((usaslln.({lly!
Richard C. Gaffney, Esquire
n!:affncv(t/)sasllo.com
Susan M. Zeamer, Esquire
g~!J,!D,~I~1:l~JhLl;.Qr.D
COMMERCE BANK! HARRISBURG
N.A.,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v.
DOCKET NO. 05-783
GETTY ACCOUNTING SERVICES,
INC.
CIVIL ACTION - LAW
Defendant.
AFFIDAVIT OF SERVICE
Richard C. Gaffney, being duly sworn according to law, deposes and says that he is the
attorney for Plaintiff in the above-captioned action; that he served on the Defendant a true and
correct copy of the Notice of Hearing on Plaintiffs Petition for Involuntary Transfer of Title and
Ownership of Vehicle by Publication in the Carlisle Sentinel on May 3,2005, as evidenced by
the Proof of Publication attached hereto and that the facts set forth in the within Affidavit are
true and correct to the best of his information and belief.
By:1L ~_ .
Richard C. Gaffney
Attorney for Plaintiff
Sworn to and subscrib((d before me
this L')dJ day of fib;;- 2005.
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. .-.. ---.- Nota'l3\ Se3l J
::;Jr.-1 J. A'1d~eI, Notary Public
City ()i l-l~rrisbiJrg, [.)3Up~'lin County
i'; .'. .~:~::.:'~~,:~: !~~~~~:,;'~,~;~~'}~~~~ <"i,~'~
. .
PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberland
Tanuny Shoemaker, Classified Advertising Manager, of The Sentinel, of the County
and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a
newspaper of general circulation in the Borough of Carlisle, County and State
aforesaid, was established December 13"', 1881, since which date THE SENTINEL has
been regularly issued in said County, and that the printed notice or publication
attached hereto is exactly the same as was printed and published in the regular editions
and issues of THE SENTINEL on the following day(s):
May 03, 2005.
COPY OF NOTICE OF PUBLICATION
NOTICE OF ACTION FOR
INVOLUNrA!lY Tfl"NSFEfl
OFmLE AND OWNERSHIP
TO VEHICLE
In Ihe Court 01 Com"mon 'Pleas of
Cumberland-County, Pennsylvania
CIVIl Action ~ Law .
., """"""." ~'I~J:ll)"Q,""'83CIY!lt0(P1;,..,:". .;
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.'>OC ,.. CO~",~lro~ c"NKlHI<R"'S.UR..I,,..A.,' ", '"
e f,eR.4.;l~ ~... ( . ~1 .: PlaIntiff 't' '.. '.
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.GETTY ACCOUNTIN(l SERVICES, INC..
. ',' Defendant"
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ro GETl"VACCbuNTINl,j S'ERVICES. INC.,:and KEITH M. OETTY.1ts president:
(pu are herebY". otlf~d,thatp'n F6B,RU,ARY ~..2.oD5',F'lajnllffl COMMERCE -
I BANKlHAf=l,AISBUJ!I~N.A. filed a Petition for Invollh'1ttuy Tra.nefer of Title and
OWn8rShl,~'pf ,V8~kiIGi; enlj0l'8edWIth8"NQUca,to Defend. against yell jrlthe:Coul1 of
.: Commi>n PleBs,of CUMBERLAND County, Penm~ylv~la~ dock~ted to No. 05-783
i Civil Term, whe'relnPl4lntlff I, sosklnd an "Order of Court 10 InvolOntarlly trJUisfer to
i Plaintiff all Utle and ownership 10 the ~2 U;XUS ES 30.0 SEDAN bearing vehicle
~ ldenlfflcatfon numl)er JTHBF300420C166a1 end 8xt1ngu,lsh.1 rlgbt, title and -
'ownershIp of any otherpersoO 10 the;sald vehicle. , ,", ,., "
iOU-ARE HER~B'i NOnFIEO TO PLEAD lolhe aliov."r~r~r~n~~':p~;fu~'n'tir a
; JudgslTlfhtwU.I.Qe e,nterestagaJOII YO,u,Jolowlng., he~rln.g,on'th~_'~.~.IU~: .
J_ , ...' _, _ , ',' _ ".', '. ,__.." .......~_
tOll ARE HEREBY 1'I0Tl~I~D that on APRIL ,8, 2006; thi cMrtliiUOa an ORDER.
!.Qra"u~ Plaln~. Motlon'for'S~ial Relief AlJlhorlz!l\g Service ByPublicatl6n end
',,:~~~Yf;~~f6~~~~r~...
Hel'lEBY i<ortilfED.}hafj,"dgomi~. i wll bti. ".ntor$d ado In.. y~u fOI."'.. w. 109
ng,~p tho.petf" orr"fh8t:~~t~ and_;~t that tlO1~ and:pla~..:,. ::- ,', ,
,~. . ,'~~ ,:,J~~~:~"~.!L:~.~~,,,~ 'lfJP_T~t7~<:_;;~:, ( '-:::._,' '_ "
Yonlfi1\.lftiHf.u~III..' . ,If,~ou~~'jqd'fon<l ~galn"l;'o cl.'m.; You
ml.int.ri"wfiiii'ep.Pf~rl1 ,pji'&9JWJIY6f.P9Iltto",oy Mt;I'flle In wrltlRg with the
CQlJO!YOJJ~ ~8tfmJe"or ObJ46.t n.'~othe claim. 8~t forth a~alna' you. You are . .
~ wamoCt that"lfyou"fall to-do so e case may proceed without you'and,a Judgement '
, "'OY~ o.to,od .g.ln.l~oubit Iho.Cou. wIIhoul.furthor nollce fOr..nY mOIlfY
clarinhtnn'tt\6 C6m'plAlilfonbf a~' otti~'r ClAim or rel.f requA8ted.by th8 Plafntlff.
: YoumayJ.lQO,n.~Y9rpr9P8t'Y,~r_Qtherrigt:'''I~.P~~~I,to.YOU. . _ ::
: ~,''':'__ -~jl. ",', ': ,',,9; ;;":",''-",_:,:,.' :''''',_,', _ ,", ""', ":,.-:'-,',.,;
tOU SHOULD tj(K~ 'rHIS.PAP~R to YOUR LAWYER ATONeE.IF YOU 00 NOT
: HAVE A LAWyaAO!l C"'~lIOT^FJ;:9RD ONE, (loro OR TELEPHONE THE
OFF.CE SET FORTH ~&tO\\lto 1'.10.0 out WHERE YOU CAN GErLEGAL
, HEL.P.
,."
"Cumberl8nd pounty
laW}'1lr ReleRal'Servlce
Cumbertand County Bar Association
32 South Bedford Street
CelllsJe._PA 17013
(800) 890.9'08
PETER-G. GOOD, ESQUIRE
SU$AN..IoI,~EAME!l, ESQUIRE. .
RICHARD c. QAFFN~Y, ESQUIRE
~MIGeL, ANI?ERSQN & SACkS. LLP
Affiant further deposes that he/ she is not
interested in the subject matter of the
aforesaid notice or advertisement, and that
.J all allegations in the foregoing statement
,! as to time, place and character of
3~~~
Sworn to and subscribed before me this
. 04th day of May, 2005.
C--A.uilV:'fA) R Ub~0
Notary lie
My commission expires: q (, (Of
COMMONWEALTH OF PENNSYLVANIA
_rial Seal
Chris'"" L. WcMe. Notary Public
Carlisle 80m. Cumbar1and Coonty
My ComrrissJon El<pIres SepL 1, 2008
Member, PennsylvanIa Association Of Notaries
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SMIGEL, ANDERSON & SACKS, LLP
River Chase Office Center
4431 North Front Street, 3'd Floor
Harrisburg,PA 17110
Peter M. Good, Esquire
mwod{.:i~sasllD.nlln
Richard C GatTney, Esquire
rllatTnev@.sasllD.com
Susan M. Zeamer, Esquire
gg'!jJJ.l~r@~g~JhLC:J)JI1
COMMERCE BANK! HARRISBURG
N.A.,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v.
DOCKET NO. 05-783
GETTY ACCOUNTING SERVICES,
INC.
CIVIL ACTION - LAW
Defendant.
AFFIDAVIT OF SERVICE
Richard C. Gaffney, being duly sworn according to law, deposes and says that he is the
attorney for Plaintiff in the above-captioned action; that he served on the Defendant a true and
correct copy of the Notice of Hearing on Plaintiffs Petition for Involuntary Transfer of Title and
Ownership of Vehicle by Publication in the Cumberland Law Journal on May 6,2005, as
evidenced by the Proof of Publication attached hereto and that the facts set forth in the within
Affidavit are true and correct to the best of his information and belief.
BY:\L<-Cl.M-,-\.SJl~
Richard C. Gaffney
Attorney for Plaintiff
Sworn to and subscribed before me
this lofth day of I Fly 2005.
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