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HomeMy WebLinkAbout14-3690 P t w �, 11 Funk& Bolton, P.A. 44, By Eric S. Schuster I.D.No. 85362 ��V,,4 o 36 South Charles Street, Twelfth Floor Baltimore,Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, * COURT OF COMMON PLEAS Plaintiff, * OF CUMBERLAND COUNTY V. * CIVIL DIVISION * MAX STONER Case No. Defendant. PRAECIPE Eric S. Schuster and Funk & Bolton, P.A., as counsel for Susquehanna Bank, request that the attached triple sealed copies of the Judgments in the amounts of $640,742.56 and $171,740.88 (plus post judgment interest and costs), in favor of Susquehanna Bank and against Max Stoner, entered by the Circuit Court for Baltimore City, Maryland, be entered in this Court as judgments in favor of Susquehanna Bank and against Max Stoner. f ox � �� Sp � a �` 0) 1Lff �Sa °r (2j� 36�Sod N 'w Respectfully submitted, r Eric S. Schuster(I.D: o. 362) Funk& Bolton, P.A. 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201-3111 410.659.4983 (telephone) 410.659.7773 (facsimile) Attorneys for Plaintiff, Susquehanna Bank Dated: June , 2014 13010"044:164010 2 1 o STATE OF MARYLAND,CITY OF BALTIMORE, SS: I,FRANK M. CONAWAY, Clerk of the Circuit Court for Baltimore City, do hereby certify that the above is a true copy of the original NOTICE OF CONFESSED JUDGMENT 24-C-13-002302 now on file in this office in the cause therein SUSQUEHANNA BANK VS STONER,MAX IN THIS TESTIMONY THEREOF,I have hereto set my hand and affix the Seal of the Circuit Court,this - 12 da JUNE 20 14 . CONA AY, Jerk I,ALFRED NANCE, Chief Judge of the Circuit Court for Baltimore City,Eighth Judicial Circuit of the State of Maryland,do hereby certify the Frank M. Conaway who has given the preceding attestation is in due form and his signature thereto is genuine. 12 day of JUNE 20 14 CHIEF GE ALFRED NANCE STATE OF MARYLAND, CITY OF BALTIMORE, SS: - I,FRANK M. CONAWAY, Clerk of the Circuit Court for Baltimore City, do hereby certify that the Honorable Alfred Nance,Chief Judge of the Circuit Court for Baltimore City,who has certified and signed the above attestation,was at the time of doing so,Judge of the said Court, duly commissioned and qualified, and that to all sets done by him in that capacity,full faith and credit is due and ought to be given; and that his signature thereto is genuine. IN TESTIMONY THEREOF,I have hereto set my hand and affix the Seal of the Circuit Court,this 12 day of JUNE 20 14 FRAN M. CONAWAY,Clerk -- N CIRCUIT COURT FOR BALTIMORE CITY R Frank M. Conaway Clerk of the Circuit Court Courthouse East 111 North Calvert Street Room 462 Baltimore, MD 21202- (410) -333-3722 , TTY for Deaf : (410') -333-4389 N 0 T I C E O F C O N F E S S E D J U D G M E N T Case Number: 24-C-13-002302 CJ C I V I L Susquehanna Bank vs OMO Science, Energy & Technology, Inc, et al ---I HEREBY CERTIFY�that�th-e�fol-lowinq Judgment= has- been recorded in this Court in the above entitled case: Judgment Against : Stoner, Max 5041 Woodbox Lane Mechanicsburg, PA 17055 Judgment in Favor of : Susquehanna Bank Judgment Ordered On: 05/15/13 Judgment Entry Date : 05/20/13 Other Fee: $ . 00 Amount of Judgment.- $637;286-:56 - Service Fee . $ . 00 - PreJudgment Interest : $ . 00 Witness Fee: $ . 00 Appearance Fee : $ . 00 Attorney Fee: $3 , 456 . 00 Filing Fee: $ . 00 Total Judgment : $640, 742 . 56 Count VII; post-judgment interest & costs You have 60 days after service of this notice upon you to file a written motion to open, modify or vacate the Judgment . IN TESTIMONY WHEREOF, I hereunto set my hand and affix the seal of this Court. AOR t n Frank M. Co away Y Clerk of the Circuit Cou tt93 Issued: 05/20/13 r * SHERIFF'F' S R E T U R N * * * Case Number: 24-C,-13-002302 Old Case Number: Susquehanna Bank vs OMO+ Science, Energy & Technology, Inc, et al To: STONER, MAX Event : Date/Time : Sheriff fee: By: Served: Time : Date : Unserved (Reason) : Instructions to Private Process : 1 . This summons is effective for service only if served within h0 _- days after the_date_ t is issued. 2 . Proof of service shall set out the name of the person served, date and the particular place and manner of service . If service is not made, Please state the reasons . 3 . Return of served or unserved process shall be made promptly.. CIRCUIT COURT FOR BALTIMORE CITY Frank M. Conaway Clerk of the Circuit Court , Courthouse East 111 North Calvert Street Room 462 Baltimore, MD 21202- (410) -333-3722 , TTY for Deaf : (410) -333-4389 N O T I C E O F C O N F E S S E D J U D G M E N T Case Number: 24-C-13-002302 CJ C I V I L Susquehanna Bank vs OMO Science, Energy & Technology, Inc, et al I HEREBY CERTIFY—that the following Judgment--has- been recorded in this Court in the above entitled case: Judgment Against : Stoner, Max _ 5041 Woodbox Lane Mechanicsburg, PA 17055 Judgment in Favor of : Susquehanna Bank Judgment Ordered On: 05/15/13 Judgment Entry Date : 05/20/13 Other Fee: $ . 00 _- Ainount"bf"Judgment:- $1681284 . 88 - Service Fee : $ . 00 PreJudgment Interest : $ . 00 Witness Fee : $ . 00 Appearance Fee : $ . 00 Attorney Fee: $3 , 456 . 00 Filing Fee : $ . 00 Total Judgment : $171, 740 . 88 Count II; post-judgment interest & costs You have 60 days after service of this notice upon you to file a written motion to open, modify or vacate the Judgment . IN TESTIMONY WHEREOF, I hereunto set my hand and affix the seal of this Court . TOR B J i Frank M. Co away Clerk of the Circuit Cour Issued: 05/20/13 �- -- .,�,,,<<� �����Iilill IIIIIIIIIIIIIIIIIIIIIiE ���Illilllllllll � -� * SHERIFF'F' S RETUR N Case Number: 24-C-13-002302 Old Case Number: Susquehanna Bank vs OMO Science, Energy & Technology, Inc, et al To: STONER, MAX Event : Date/Time: Sheriff fee : By: Served: Time : Date Unserved (Reason) : Instructions to Private Process : 1 . This summons is effective for service only if served within 60 days after the elate it issued.' 2 . Proof of service shall set out the name of the person served, date and the particular place and manner of service. If service is not made, Please state the reasons . 3 . Return of served or unserved process shall be made promptly. r a a SUSQUEHANNA BANK * IN THE 1570 Manheim Pike Lancaster, Pennsylvania 17604 * CIRCUIT COURT Plaintiff, * FOR V. * BALTIMORE CITY OMO SCIENCE,ENERGY & * Case No. 24CI3002302 TECHNOLOGY,INC., t/a LUBES & SPECIALTY PRODUCTS 2225 Evergreen-Str_eet ___ - Baltimore,Maryland 21210 MAX STONER 5041 Woodbox Lane Mechanicsburg, Pennsylvania 17055 JAMES RIDDICK 110 Hannum Drive Bear,Delaware 19701 GERALD HILL 12307 Valley Hills Drive Houston, Texas 77071 JAMEL DEVELOPMENT CO., LLC 12715 Buckhardt Court Clinton,Maryland 20735 Defendants. * * * * * * * * * * * * * * AMENDED ORDER 6t4�l (z) Upon consideration of thej�omplaint and Confession of Judgment�annd related pleadings filed in this matter, and pursuant to Maryland Rule 2-611(b), it is this day of fua , 2013, hereby ORDERED, that the Court directs the Clerk of the Court to enter judgment as follows: 1 x A. JUDGMENT BY CONFESSION is hereby entered in the above-captioned case as . � f to Count I on this �p�L day of $l A t",/V , 2013; by the Circuit Court for Baltimore City, r /4 Maryland, in favor of the Plaintiff, Susquehanna Bank, and against Defendant OMO Science, Energy & Technology, Inc., t/a Lubes & Specialty Products, in the amount of$168,284.88, plus actual attorneys' fees of$3,456.00,pre judgment interest at the rate of$26.65 per day after April 15, 2013, until the date of entry of judgment,post judgment interest, and costs. B. JUDGMENT BY CONFESSION is hereby entered in the above-captioned case as to Count 11 on this l day of tip`` , 2013, by the Circuit Court for Baltimore City, Maryland, in favor of the Plaintiff, Susquehanna Bank, and against Defendant Max_Stoner, in the amount of$168,284.88, plus actual attorneys' fees of$3,456.00, pre judgment interest at the rate of $26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. C. JUDGMENT BY CONFESSION is hereby entered in the above-captioned case as f to Count III. on this day of -��, 2013, by the Circuit Court for Baltimore City, J Maryland, in favor of the Plaintiff, Susquehanna Bank, and against Defendant James Riddick, in the amount of$168,284.88, plus actual attorneys' fees of$3,456.00, pre judgment interest at the rate of$26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. D. JUDGMENT BY CONFESSION is hereby entered in the above-captioned case as to Count IV on this day of� ' 2013, by the Circuit Court for Baltimore City, Maryland, in favor of the Plaintiff, Susquehanna Bank, and against Defendant Gerald Hill, in the amount of$168,284.88, plus actual attorneys' fees of$3,456.00, pre judgment interest at the rate 2 of $26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. E. JUDGMENT BY CONFESSION is hereby entered in the above-captioned case as to Count V on this day of + � , 2013, by the Circuit Court for Baltimore City, tYf Maryland, in favor of the Plaintiff, Susquehanna Bank, and against Defendant Jamel Development Co., LLC, in the amount of$168,284.88, plus actual attorneys' fees of$3,456.00, pre judgment interest at the rate of$26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. F. JUDGMENT BY CONFESSION is hereby entered in the above-captioned case as to Count VI on this day of ', 2013, by the Circuit Court for Baltimore City, 0i Maryland, in favor of the Plaintiff, Susquehanna Bank, and against Defendant OMO Science, Energy & Technology, Inc., t/a Lubes & Specialty Products, in the amount of$637,286.56, plus actual attorneys' fees of$3,456.00, pre judgment interest at the rate of$66.31 per day after April 15, 2013, until the date of entry of judgment,post judgment interest, and costs. G. JUDGMENT BY CONFESSION is hereby entered in the above-captioned case as .' 'V `y to Count VII on this day ofi ' , 2013, by the Circuit Court for Baltimore City, Maryland, in favor of the Plaintiff, Susquehanna Bank, and against Defendant Max Stoner, in the amount of$637,286.56, plus actual attorneys' fees of$3,456.00, pre judgment interest at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. H. JUDGMENT BY CONFESSION is hereby entered in the above-captioned case as to Count VIII on thisday of t , 2013, by the Circuit Court for Baltimore City, Yj Maryland, in favor of the Plaintiff, Susquehanna Bank, and against Defendant James Riddick, in 3 + u the amount of$637,286.56, plus actual attorneys' fees of$3,456.00, pre judgment interest at the rate of$66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. I. JUDGMENT BY CONFESSION is hereby entered in the above-captioned case as to Count IX on this �6 day of � , 2013, by the Circuit Court for Baltimore City, Maryland, in favor of the Plaintiff, Susquehanna Bank, and against Defendant Gerald Hill, in the amount of$637,286.56, plus actual attorneys' fees of$3,456.00, pre judgment interest at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. J. JUDGMENT BY CONFESSION is hereby entered in the above-captioned case as to Count X on this; oda y of �. , 2013, by the Circuit Court for Baltimore City, Maryland, in favor of the Plaintiff, Susquehanna Bank, and _against Defendant Jamel Development Co., LLC, in the amount of$637,286.56, plus actual attorneys' fees of$3,456.00, pre judgment interest at the rate of$66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. K. The Court finds from the Affidavit of Brian Braungard that the attorneys' fees sought were those actually incurred to date hv.$usauehannaBank.and_are reasonable. JZ1F)GE PA1VI.1!LA J. WHITE TF e Judge'&slgriatupr appears S / on-the onginal.document. Judge,'Cii-dCourt"fol-M - to C4,Maryland cc: Eric S. Schuster, Esquire V Funk& Bolton, P.A. 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 13010.044:154457 4 SUSQUEHANNA BANK * IN THE Plaintiff, * CIRCUIT COURT V. * FOR OMO SCIENCE, ENERGY & TECHNOLOGY,* BALTIMORE CITY et al. Defendant. * CASE NO.: 24-C-13-002302 * * * * * * * * * * * * * * ORDER Pending before this Court is Plaintiff's "Complaint and Confession of Judgment" (1). Maryland Rule 2-611(a) prescribes a specific form of affidavit that must accompany each complaint for a confessed judgment. Comparing Plaintiff's Affidavit with the requirements of Md. Rule 2-611, Plaintiff's Affidavit fails to conform to the requirement that the Affidavit include a computation of the amount due under the instrument, specifically, the "Other Charges" of$60.00 in Counts I through V, .and,$74,5 19.83 in Counts VI through X, respectively. The affidavit must contain"sufficient factual detail to demonstrate that the sum claimed was in fact a liquidated amount arrived at by arithmetical computation made in accordance with the terms of the agreement." Second Shift, Inc. v. Reservoir Capital Corp., 124 Md. App. 14, 22 (1998). The affidavit may not simply contain a "bald, conclusory statement of the affiant that a particular sum was due."Id. Upon consideration of the Court file, Plaintiff's "Complaint and Confession of Judgment" (1) and the attached Affidavit and exhibits, and Md. Rule 2-611, it is this Lkay of May, 2013 hereby ORDERED that Plaintiff's "Complaint for Judgment by Confession" is DISMISSED without prejudice and with leave to amend in conformity with Md. Rule 2-611(a). . JUDGE EAM :I�A J.WHITE ry 11,�e Judge's.signature appears j _on-the 6ii6h4l document. Pamela J. White, Judge Circuit Court for Baltimore City. Part 7 Page 1 of 1 * T SUSQUEHANNA BANK IN THE r'✓ 1570 Manheim Pike * CIRCUIT COURT Lancaster,Pennsylvania 17604 * FOR Plaintiff, TORE CITY BALTIMORE V. OMO SCIENCE,ENERGY & * Case No. 24013002302 TECHNOLOGY,INC., t/a LUBES & SPECIALTY PRODUCTS 2225 Evergreen Street Baltimore, Maryland 21210 NIAX STONER 5041 Woodbox Lane Mechanicsburg,Pennsylvania 17055 JAMES RIDDICK X 110 Hannum Drive Bear, Delaware 14701 7t GERALD HILL 12307 Valley Hills Drive Houston, Texas 77071 JANIIEL DEVELOPMENT CO.,LLC 12715 Buckhardt Court Clinton,Maryland 20735 Defendants. * * * * * * * * * AMENDED COMPLAINT AND CONFESSION OF JUDGMENT Plaintiff, Susquehanna Bank, by its attorneys, Eric S. Schuster and Funk & Bolton, P.A., hereby sues the Defendants, OMO Science, Energy & Technology, Inc., t/a Lubes & Specialty ll, and Jamel Development Co., LLC, and for its Products,Max Stoner, James Riddick, Gerald Hi causes of action states as follows: 1 FACTS COMMON TO ALL COUNTS 1. Plaintiff, Susquehanna Bank f/k/a Susquehanna Patriot Bank ("Plaintiff"), has a place of business in Lancaster, Pennsylvania, 2. Defendant OMO Science, Energy & Technology, Inc., t/a Lubes & Specialty Products COMO"), is, upon information and belief, a Texas corporation which has a place of business in Baltimore, Maryland. 3. Defendant Max Stoner ("Stoner") is, upon information and belief, a Pennsylvania resident residing in Mechanicsburg, Pennsylvania. 4. Defendant James Riddick ("Riddick") is, upon information and belief, a Delaware resident residing in Bear, Delaware. 5. Defendant Gerald Hill ("Ell") is, upon information and belief, a Texas resident residing in Houston, Texas. 6. Defendant Jamel Development Co., LLC ("Jamel"), is, upon information and belief, a Maryland limited liability company which has its principal place of business in Maryland. 7. Jurisdiction and venue are proper in this Court as the Defendants consented to this Court entering the relief requested herein. S. Plaintiff made a loan in the original principal amount of $350,000.00 ("Loan One") to OMO as evidenced by an U.S. Small Business Administration Note dated November 20, 2006, to the order of the Plaintiff in the aforesaid principal sum ("Note One"). A true and accurate copy of Note One is attached hereto as Exhibit "A" and is incorporated herein by reference. 2 9. The obligations due and owing under Note One are guaranteed by Stoner pursuant to a U.S. Small Business Administration Unconditional Limited Guarantee dated November 20, 2006, executed by Stoner ("First Stoner Guaranty"). A true and accurate copy of the First Stoner Guaranty is attached hereto as Exhibit "B" and is incorporated herein by reference. 10. The obligations due and owing under Note One are guaranteed by Riddick pursuant to a U.S. Small Business Administration Unconditional Limited Guarantee dated November 20, 2006, executed by Riddick ("First Riddick Guaranty"). A true and accurate copy of the First Riddick Guaranty is attached hereto as Exhibit "C" and is incorporated herein by reference. 11. The obligations due and owing under Note One are guaranteed by Hill pursuant to a U.S. Small Business Administration Unconditional Limited Guarantee dated November 20, 2006, executed by Hill ("First Hill Guaranty"). A true and accurate copy of the First Hill Guaranty is attached hereto as Exhibit"D"and is incorporated herein by reference. 12. The obligations due and owing under Note One are guaranteed by Jamel pursuant to a Commercial Guaranty dated April 16, 2007, executed by Jamel (`.`Jamel Guaranty"). A true and accurate copy of the Jamel Guaranty is attached hereto as Exhibit "E" and is incorporated herein by reference. 13. Note One, First Stoner Guaranty, First Riddick Guaranty, First Hill Guaranty, Jamel Guaranty, and all other documents executed in connection with or related to the Loan One are hereinafter collectively referred to as the "Loan One Documents." 14. Plaintiff made another loan in the original principal amount of $562,000.00 ("Loan Two") to'OMO as evidenced by Promissory Note dated April 16, 2007, to the order of 3 4 d the Plaintiff in the aforesaid principal sum ("Note Two"). A true and accurate copy of Note TR'o is attached hereto as Exhibit"F" and is incorporated herein by reference. 15. The obligations due and owing under Note Two are guaranteed by Stoner pursuant to a Commercial Guaranty dated April 16, 2007, executed by Stoner ("Second Stoner Guaranty"). A true and accurate copy of the Second Stoner Guaranty is attached hereto as Exhibit "G" and is incorporated herein by reference. 16. The obligations due and owing under Note Two are guaranteed by Riddick pursuant to a Commercial Guaranty dated.�ipril 16, 2007, executed by Riddick ("Second Riddick Guaranty"). A true and accurate copy of the Second Riddick Guaranty is attached hereto as Exhibit"H"and is incorporated herein by reference. 17. The obligations due and owing under Note Two are guaranteed by Hill pursuant to a Commercial Guaranty dated April 16, 2007, executed by Hill ("Second Hill Guaranty"). A true and.accurate copy of the Second Hill Guaranty is attached hereto as Exhibit "I" and is incorporated herein by reference. 18. The obligations due and owing under Note Two are guaranteed by Jamel pursuant to the Jamel Guaranty. 19. Note Two, Second Stoner Guaranty, Second Riddick Guaranty, Second Hill Guaranty, Jamel. Guaranty, and all other documents executed in connection with or related to Loan Two are hereinafter collectively referred to as the "Loan Two Documents." 20. Following default under Loan One and Loan Two demand was made upon the Defendants pursuant to letters dated April 3, 2013, copies of which are attached hereto collectively as Exhibit "J" and are incorporated herein by reference. To date, the sums due and 4 owing to the Plaintiff under Loan One, Loan Two the Loan One Documents and the Loan Two Documents have not been remitted to the Plaintiff. COUNT 21. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-20 of this Complaint as if fully set forth herein. 22. Under the terms and conditions of Note One, OMO authorized any attorney designated by the Plaintiff,to appear on behalf of OMO and to confess judgment against it for all sums owed pursuant to Note One and agreed to pay the Plaintiff s attorneys' fees incurred. 23. As of April 15, 2013, there is due and o«ring to the Plaintiff from OMO Science, Energy & Technology, Inc., t/a Lubes & Specialty Products under the terms of Note One the total aggregate amount of$171,740.88, consisting of an unpaid principal balance of$159,909.01, accrued and unpaid interest of$7,903.31, satisfaction fee of$60.00, late charges of$412.56 and ;attorneys' fees of $3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of $26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against OMO Science, Energy & Technology, Inc., t/a.Lubes & Specialty Products pursuant to the terms of Note One in the amount of$168,284.88; plus attorneys' fees of $3,456.00, pre-judgment interest at the rate of$26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. COUNT II 24. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-23 of this Complaint as if fully set forth herein. 5 Y O . 25. Under the terns and conditions of the First Stoner Guaranty, Stoner guaranteed to repay all obligations due and owing with respect to Loan One. Under the terms and conditions. of the First Stoner Guaranty, Stoner authorized any attorney designated by the Plaintiff to appear on his behalf and to confess judgment against him for all sums owed pursuant to Note One and the First Stoner Guaranty, and agreed to pay the Plaintiff's attorneys, fees incurred. 26. As of April 15, 2013, there is due and Owing to the Plaintiff from Max Stoner, under the terms and conditions of Note One and the .First Stoner Guaranty the total aggregate amount of $171,740.88, consisting of an unpaid principal balance of $159,909.01, accrued and unpaid interest of $7,903.31, satisfaction fee of $60.00, late charges of $412.56 and attorneys' fees of$3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$26.65 per day after April 15, 2013, until the date of entry of judgment, post- judgment interest, and costs. WHEREFORE, Plaintiff, Susq»Phanna Bank, prays that judgment by confession be . entered in its favor against Max Stoner, pursuant to the terms of Note One and the First Stoner Guaranty, in the amount of$168,284.88, plus attorneys, fees of$3,456.00, pre judgment interest at the rate of $26.65 per day after April 15, 2013, until the date of entry of judgment, post- judgment interest, and costs. COUNT III 27. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-26 of this Complaint as if fully set forth herein. 28. Under the terms and conditions of the First Riddick Guaranty, Riddick guaranteed to repay all obligations due and owing with respect to Loan One. Under the terms and conditions of the First Riddick Guaranty, Riddick authorized any attorney designated by the Plaintiff to 6 appear on his behalf and to confess judgment against him for all sums owed pursuant to Note One and the First Riddick Guaranty, and agreed to pay the Plaintiff's attorneys' fees incurred. 29. As of April 15, 2013, there is due and owing to the Plaintiff from James Riddick, under the terms and conditions of Note One and the First Riddick Guaranty the total aggregate amount of $171,740.88, consisting of an unpaid principal balance of $159,909.01, accrued and unpaid interest of $7,903.31, satisfaction fee of $60.00, late charges of $412.56 and attorneys' fees of$3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$26.65 per day after April 15, 2013, until the date of entry of judgment, post- judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against James Riddick, pursuant to the terms of Note One and the First Riddick Guaranty, in the amount of$168,284.88, plus attorneys' fees of$3,456.00,pre judgment interest at the rate of $26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. COUNT IV 30. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-29 of this Complaint as if fully set forth herein. . 31. Under the terms and conditions of the-First Hill Guaranty, Hill guaranteed to repay all obligations due and owing with respect to Loan One. Under the terms and conditions of the First Hill Guaranty, Hill authorized any attorney designated by the Plaintiff to appear on his behalf and to confess judgment against him for all sums owed pursuant to Note One and the First Hill Guaranty, and agreed to pay the Plaintiff's attorneys' fees incurred. 7 32. As of April 15, 2013, there is due and owing to the Plaintiff from Gerald Hill. under the terms and conditions of Note One and the First Hill Guaranty the total aggregate amount of$171,740.88, consisting of an unpaid principal balance of $159,909.01, accrued and unpaid interest of$7,903.31, satisfaction fee of$60.00, late charges of$412.56 and attorneys' fees of$3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$26.65 per day after April 15, 2013, until the date of entry of judgment, post- judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Gerald Hill, pursuant to the terms of Note One and the First Hill Guaranty, in the amount of$168,284.88, plus attorneys' fees of$3,456.00, pre-judgment interest at the rate of $26.65 per day after Aprii 15, 2013, until the date of entry of judgment, post- judgment interest, and costs. COUNT V 33. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-32 of this Complaint as if fully set forth herein. 34. Under the terms and conditions of the Jamel Guaranty, Jamel guaranteed to repay all obligations due and owing with respect to Loan One. Under the terms and conditions of the Jamel-Guaranty,-Jamel authorized any attorney designated by the Plaintiff to appear on its behalf and to confess judgment against it for all sums owed pursuant to Note One and the Jamel Guaranty, and agreed to pay the Plaintiff s attorneys' fees incurred. 35. As of April 15, 2013, there is due and owing to the Plaintiff from Jamel Development Co., LLC, under the terms and conditions of Note One and the Jamel Guaranty the total aggregate amount of$171,740.88, consisting of an unpaid principal balance of$159,909.01, 8 v accrued and unpaid interest of$7,903.31, satisfaction fee of$60.00, late charges of$412.56 and attorneys' fees of $3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of $26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Jamel Development Co., LLC, pursuant to the terms of Note One and the Jamel Guaranty, in the amount of $168,284.88, plus attorneys' fees of $3,456.00, pre- judgment interest at the rate of.$26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. COUNT VI 36. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-34 of this Complaint as if fully set forth herein. 37. Under the terms and conditions of Note Two, OMO authoized any attorney designated by the Plaintiff to appear on its behalf and to confess judgment against it for all sums owed pursuant to Note Two, and agreed to pay the Plaintiff's attorneys' fees incurred. 38. As of April 15, 2013, there is due and owing to the Plaintiff from OMO Science, Energy & Technology Inc., t/a Lubes & Specialty Products under the terms and conditions of Note Two the total aggregate amount of$640,742.56, consisting of an unpaid principal balance of$561,727.97, accrued and unpaid interest of$1,989.46, late charges of$1,193.68, satisfaction fee of $60.00, forced place insurance of $28,616.32, paid outstanding real estate taxes of $43,629.13 and attorneys' fees of$3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. 9 V y WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against OMO Science, Energy & Technology Inc., t/a Lubes & Specialty Products, pursuant to the terms of Note Two in the amount of$637,286.56, plus attomeys' fees of$3,456.00, pre judgment interest at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment,post-judgment interest, and costs. COUNT VII 39. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-38 of this Complaint as if fully set forth herein. 40. Under the terms and conditions of the Second Stoner Guaranty, Stoner guaranteed to repay all obligations due and owing with respect to Loan Two. Under the terms and conditions of the Second Stoner Guaranty, Stoner authorized any attorney designated by the Plaintiff to appear on his behalf and to confess judgment against him for all sums owed pursuant to Note Two and the Second Stoner Guaranty, and agreed to pay the Plaintiff s attorneys' fees incurred. 41. As of April 15, 2013, there is due and owing to the Plaintiff from Max Stoner under the terms and conditions of Note Two and the Second Stoner Guaranty the total aggregate amount of$640,742.56, consisting of an unpaid principal balance of$561,727.97, accrued and unpaid interest of $1,989.46, late charges of$1,193.68, satisfaction fee of$60.00, forced place insurance of$28,616.32, paid outstanding real estate taxes of$43,629.13 and attorneys' fees of $3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$66.31 per day after April'15, 2013, until the date of entry of judgment, post judgment interest, and costs. 10 WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Max Stoner, pursuant to the terms of Note Two and the Second Stoner Guaranty, in the amount of$637,286.56, plus attorneys' fees of$3,456.00, pre-judgment interest at the rate of $6.6.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. COUNT VIII 42. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-41 of this Complaint as if fully set forth herein. 43. Under the terms and conditions of the Second Riddick Guaranty, Riddick guaranteed to repay all obligations due and owing with respect to Loan Two. Under the terms and conditions of the Second Riddick.Guaranty, Riddick authorized any attorney designated by the Plaintiff to appear on his behalf and to confess judgment against him for all sums owed p1irsuant to Note Two and the Second Riddick Guaranty, and agreed to pay the Plaintiffs attorneys' fees incurred. 44. As of April 15, 2013, there is due and owing to the Plaintiff from Riddick under the terms and conditions of Note Two and the Second Riddick Guaranty the total aggregate amount of $640,742.56, consisting of an unpaid principal balance of$561,727.97, accrued and unpaid interest of$1,989.46,-, late charges of$1,1-93.68, satisfaction fee of$60.00, forced place insurance of$28,616.32, paid outstanding real estate taxes of$43,629.13 and attorneys' fees of $3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$66.31 per day after April 15, 2013, until the date of entry of judgment, post-judgment interest, and costs. 11 a n WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against James Riddick, pursuant to the terms of Note Two and the Second Riddick Guaranty, in the amount of$637,286.56,plus attorneys' fees of$3,456.00, pre-judgment interest at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. COUNT IX 45. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-44 of this Complaint as if fully set forth herein. 46. Under the terms and conditions of the Second Hill Guaranty, Hill guaranteed to repay all obligations due and owing with respect to Loan Two. Under the terms and conditions of the Second Hill Guaranty, Hill authorized any attorney designated by the Plaintiff to appear on his behalf and to confess judgment against him for all sums owed pursuant to Note Two and the Second Hill Guaranty, and agreed to ;gay the Plaintiff s attorneys' f;;es incurred. -- 47. As of April 15, 2013, there is due and owing to the Plaintiff from Gerald.Hill under the terms and conditions of Note Two and the Second Hill Guaranty the total aggregate amount of$640,742.56, consisting of an unpaid principal balance of$642,883.94, consisting of an unpaid principal balance of $561,727.97, accrued and unpaid interest of $1,989.46, late charges of $1,1-93.68, satisfaction fee of $60.00, forced place insurance of $28,616.32, paid outstanding real estate taxes of$43,629.13 and attorneys' fees of$3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$66.31 per day after April,201.3,until the date of entry of judgment, post-judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Gerald Hill, pursuant to the terms of Note Two and the Second Hill 12 i i Guaranty, in the amount of$637,286.56, plus attorneys' fees of$3,456.00, pre-judgment interest at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment, post- judgment interest,and costs. COUNT X 48. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-47 of this Complaint as if fully set forth herein. 49. Under the terms and conditions of the Jamel Guaranty, Jame! guaranteed to repay all obligations due and owing with respect to Loan Two. Under the terms and conditions of the Jamel Guaranty, Jamel authorized any attorney designated by the Plaintiff to appear on its behalf and to confess judgment against it for all sums owed pursuant to Note .Two and the Jamel - Guaranty, and agreed to pay the Plaintiff's attorneys' fees incurred. - 50. As of April 15, 2013, there is due and owing to the Plaintiff from Jamel Development Co., LLC under the terms and conditions of Note Two and the Jamel Guaranty the total aggregate amount of$640,742.56, consisting of an unpaid principal balance of$561,727.97, accrued and unpaid interest of$1,989.46, late charges of $1,193.68, satisfaction fee of $60.00, forced place insurance of $28,616.32, paid outstanding real estate taxes of $43,629.13 and attorney-s'-fees of $3,456.00. -Interest continues to accrue on the unpaid-principal-amount due under Note One at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Jamel Development Co., LLC, pursuant to the terms of Note Two and the Jamel Guaranty, in the amount of $637,286.56, plus attorneys' fees of $3,456.00, pre- 13 judgment interest at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. l -S7, Eric S. Schuster FUNK& BOLTON, P.A. 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201-3111 410.659.4983 (telephone) 410.659.7773 (facsimile) Attorneys for Plaintiff, Susquehanna Bank Dated: Mayr, 2013 13010.044:154568 14 • J SUSQUEHANNA BANK * IN THE 1570 Manheim Pike Lancaster, Pennsylvania 17604 * CIRCUIT COURT Plaintiff, * FOR V. * BALTIMORE CITY OMO SCIENCE,ENERGY & Case No: C N-� TECHNOLOGY, INC., t/a LUBES & SPECIALTY PRODUCTS 2225 Evergreen-Street---- Baltimore, Maryland 21210 MAX STONER 5041 Woodbox Lane Mechanicsburg, Pennsylvania 17055 JAMES RIDDICK '110 Hannum Drive Bear, Delaware 19701 GERALD HILL 12307 Valley Hills Drive �` `' `' ' `'`"` ' Houston, Texas 77071 JAMEL DEVELOPMENT CO.,LLC 12715 Buckhardt Court Clinton, Maryland 20735 Defendants. * * * * * * * * * * * * * * COMPLAINT AND CONFESSION OF JUDGMENT Plaintiff, Susquehanna Bank, by its attorneys, Eric S. Schuster and Funk & Bolton, P.A., hereby sues the Defendants, OMO Science, Energy & Technology, Inc.', t/a Lubes & Specialty Products, Max Stoner, James Riddick, Gerald Hill, and Jamel Development Co., LLC, and for its causes of action states as follows: 1 FACTS COMMON TO ALL COUNTS 1. Plaintiff, Susquehanna Bank f/k/a Susquehanna Patriot Bank ("Plaintiff'), has a place of business in Lancaster, Pennsylvania. 2. Defendant OMO Science, Energy & Technology, Inc., t/a Lubes & Specialty Products ("OMO"), is, upon information and belief, a Texas corporation which has a place of business in Baltimore, Maryland. 3. Defendant Max Stoner ("Stoner") is, upon information and belief, a Pennsylvania resident residing in Mechanicsburg, Pennsylvania. 4. Defendant James Riddick ("Riddick") is, upon information and belief, a Delaware resident residing in Bear, Delaware. 5. Defendant Gerald Hill ("Hill") is, upon information and belief, a Texas resident residing in Houston, Texas. 6. Defendant Jamel Development Co., LLC ("Jamel"), is, upon information and belief, a Maryland limited liability company which has its principal place of business .in Maryland. 7. Jurisdiction and venue are proper in this Court as the Defendants consented to this Court entering the relief requested herein. 8. Plaintiff made a loan in the original principal amount of $350,000.00 ("Loan One") to OMO as evidenced by an U.S. Small Business Administration Note dated November 20, 2006, to the order of the Plaintiff in the aforesaid principal sum ("Note One"). A true and accurate copy of Note One is attached hereto as Exhibit "A" and is incorporated herein by reference. 2 7 9. The obligations due and owing under Note One are guaranteed by Stoner pursuant to a U.S. Small Business Administration Unconditional Limited Guarantee dated November 20, 2006, executed by Stoner ("First Stoner Guaranty"). A true and accurate copy of the First Stoner Guaranty is attached hereto as Exhibit"B" and is incorporated herein by reference. 10. The obligations due and owing under Note One are guaranteed by Riddick pursuant to a U.S. Small Business Administration Unconditional Limited Guarantee dated November 20, 2006, executed by Riddick ("First Riddick Guaranty"). A true and accurate copy of the First Riddick Guaranty is attached hereto as Exhibit "C" and is incorporated herein by reference. 11. The obligations due and owing under Note One are guaranteed by Hill pursuant to a U.S. Small Business Administration Unconditional Limited Guarantee dated November 20, 2006, executed by Hih ("First Hill Guaranty"). A true and accurate copy of the First Hill Guaranty is attached hereto as Exhibit"D" and is incorporated herein by reference. 12. The obligations due and owing under Note One are guaranteed by Jamel pursuarit to a Commercial Guaranty dated April 16, 2007, executed by Jamel ("Jamel Guaranty"). A true and accurate copy of the Jamel Guaranty is attached hereto as Exhibit `B" and is incorporated herein by reference. 13. Note One, First Stoner Guaranty, First Riddick Guaranty, First Hill Guaranty, Jamel Guaranty, and all other documents executed in connection with or related to the Loan One are hereinafter collectively referred to as the"Loan One Documents." 14. Plaintiff made another loan in the original principal amount of $562,000.00 ("Loan Two") to OMO as evidenced by Promissory Note dated April 16, 2007, to the order of 3 J the Plaintiff in the aforesaid principal sum ("Note Two'). A true and accurate copy of Note Two is attached hereto as Exhibit "F" and is incorporated herein by reference. 15. The obligations due and owing under Note Two are guaranteed by Stoner pursuant to a Commercial Guaranty dated April 16, 2007, executed by Stoner ("Second Stoner Guaranty"). A true and accurate copy of the Second Stoner Guaranty is attached hereto as Exhibit"G"and is incorporated herein by reference. 16. The obligations due and owing under Note Two are guaranteed by Riddick pursuant to a Commercial Guaranty dated April 16, 2007, executed by Riddick("Second Riddick Guaranty"). A true and accurate copy of the Second Riddick Guaranty is attached hereto as Exhibit"H" and is incorporated herein by reference. 17. The obligations due and owing under Note Two are guaranteed by Hill pursuant to a Commercial Guaranty dated April 16, 2007, executed by Hill ("Second Hill Guaranty"). A true and accurate copy of the Second Hill Guaranty is attached hereto as Exhibit "P' and is incorporated herein by reference. 18. The obligations due and owing under Note Two are guaranteed by Jamel pursuant to the Jamel Guaranty. 19. Note Two, Second Stoner Guaranty, Second Riddick Guaranty, Second Hill Guaranty, Jamel Guaranty, and all other documents executed in connection with or related to Loan Two are hereinafter collectively referred to as the "Loan Two Documents." 20. Following default under Loan One and Loan Two demand was made upon the Defendants pursuant to letters dated April 3, 2013, copies of which are attached hereto collectively as Exhibit "J" and are incorporated herein by reference. To date, the sums due and 4 n j owing to the Plaintiff under Loan One, Loan Two the Loan One Documents and the Loan Two Documents have not been remitted to the Plaintiff. COUNT I 21. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-20 of this Complaint as if fully set forth herein. 22. Under the terms and conditions of Note One, OMO authorized any attorney designated by the Plaintiff to appear on behalf of OMO and to confess judgment against it for all sums owed pursuant to Note One and agreed to pay the Plaintiff's attorneys' fees incurred. 23. As of April 15, 2013, there is due and owing to the Plaintiff from OMO Science, Energy & Technology, Inc., t/a Lubes & Specialty Products under the terms of Note One the total aggregate amount of$171,740.88, consisting of an unpaid principal balance of$159,909.01, accrued and unpaid interes, of$7,903.31, other charges of$60.00, late charges of$412.56 and attorneys" fees of $3,456.00. Interest continues to accrue on the unpaid principal amount-due under Note One at the rate of $26.65 per day after April 15, 2013, until the date of entry of judgment,post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against OMO Science, Energy & Technology, Inc., t/a Lubes & Specialty, . Products pursuant to'the terms of Note One in the amount of$168,284.88, plus attorneys' fees of $3,456.00, pre judgment interest at the rate of$26.65 per day after April 15, 2013, until the date of entry of judgment,post judgment interest, and costs. COUNT II 24. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-23 of this Complaint as if fully set forth herein. 5 25. Under the terms and conditions of the First Stoner Guaranty, Stoner guaranteed to repay all obligations due and owing with respect to Loan One. Under the terms and conditions of the First Stoner Guaranty, Stoner authorized any attorney designated by the Plaintiff to appear on his behalf and to confess judgment against him for all sums owed pursuant to Note One and the First Stoner Guaranty, and agreed to pay the Plaintiff's attorneys'fees incurred. 26. As of April 15, 2013, there is due and owing to the Plaintiff from Max Stoner, under the terms and conditions of Note One and the First Stoner Guaranty the total aggregate amount of$171,740.88, consisting of an unpaid principal balance of $159,909.01, accrued and unpaid interest of$7,903.31, other charges of$60.00, late charges of$412.56 and attorneys' fees of$3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$26.65 per day after April 15, 2013,until the date of entry of judgment,post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Max Stoner, pursuant to the terms of Note One and the First Stoner Guaranty, in the amount of$168,284.88, plus attorneys' fees of$3,456.00, pre judgment interest at the rate of $26.65 per day after April 15, 2013, until the date of entry of judgment, post- judgment interest, and costs. COUNT III 27. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-26 of this Complaint as if fully set forth herein. 28. Under the terms and conditions of the First Riddick Guaranty, Riddick guaranteed to repay all obligations due and owing with respect to Loan One. Under the terms and conditions of the First Riddick Guaranty, Riddick authorized any attorney designated by the Plaintiff to 6 h 7 appear on his behalf and to confess judgment against him for all sums owed pursuant to Note One and the First Riddick Guaranty, and agreed to pay the Plaintiff's attorneys' fees incurred. 29. As of April 15, 2013, there is due and owing to the Plaintiff from James Riddick, under the terms and conditions of Note One and the First Riddick Guaranty the total aggregate amount of $171,740.88, consisting of an unpaid principal balance of $159,909.01, accrued and unpaid interest of$7,903.31, other charges of$60.00, late charges of$412.56 and attorneys' fees of$3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against James Riddick, pursuant to the terms of Note One 'and the First Riddick Guaranty, in the amount of$168,284.88, plus attorneys' fees of$3,456.00, pre judgment interest at the rate of $26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. COUNT IV 30. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-29 of this Complaint as if fully set forth herein. 31. Under the terms and conditions of the First Hill Guaranty, Hill guaranteed to repay all obligations due and owing with respect to Loan One. Under the terms and conditions of the First Hill Guaranty, Hill authorized any attorney designated by the Plaintiff to appear on his behalf and to confess judgment against him for all sums owed pursuant to Note One and the First Hill Guaranty, and agreed to pay the Plaintiff s attorneys' fees incurred. 7 Q 32. As of April 15, 2013, there is due and owing to the Plaintiff from Gerald Hill, under the terms and conditions of Note One and the First Hill Guaranty the total aggregate amount of $171,740.88, consisting of an unpaid principal balance of$159,909.01, accrued and unpaid interest of$7,903.31, other charges of$60.00, late charges of$412.56 and attorneys' fees of$3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$26.65 per day after April 15, 2013,until the date of entry of judgment, post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Gerald Hill, pursuant to the terms of Note One and the First Hill Guaranty, in the amount of$168,284.88, plus attorneys' fees of$3,456.00, pre judgment interest at the rate of $26.65 per day after April 15, 2013, until the date of entry of judgment, post- judgment interest, and costs. C'OUNT V 33. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-32 of this Complaint as if fully set forth herein. 34. Under the terms and conditions of the Jamel Guaranty, Jamel guaranteed to repay all obligations due and owing with respect to Loan One. Under the terms and conditions of the Jamel Guaranty, Jamel authorized any attorney designated by the Plaintiff to appear on its behalf and to confess judgment against it for all sums owed pursuant to Note One and the Jamel Guaranty, and agreed to pay the Plaintiff's attorneys' fees incurred. 35. As of April 15, 2013, there is due and owing to the Plaintiff from Jamel Development Co., LLC, under the terms and conditions of Note One and the Jamel Guaranty the total aggregate amount of$171,740.88, consisting of an unpaid principal balance of$159,909.01, 8 accrued and unpaid interest of $7,903.31, other charges of$60.00, late charges of$412.56 and attorneys' fees of$3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of $26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Jamel Development Co., LLC, pursuant to the terms of Note One and the Jamel Guaranty, in the amount of $168,284.88, plus attorneys' fees of $3,456.00, pre- judgment interest at the rate of$26.65 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. COUNT VI 36. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-34 of this Complaint as if fully set forth herein. 37. Under the terms and conditions of Note Two, OMO authorized any attorney designated by the Plaintiff to appear on its behalf and to confess judgment against it for all sums owed pursuant to Note Two, and agreed to pay the Plaintiff's attorneys' fees incurred. 38. As of April 15, 2013, there is due and owing to the Plaintiff from OMO Science, Energy & Technology Inc., t/a Lubes & Specialty Products under the terms and conditions of Note Two the total aggregate amount of$642,883.94, consisting of an unpaid principal balance of $561,727.97, accrued and unpaid interest of $1,989.46, other charges of $74,519.83, late charges of$1,193.68 and attorneys' fees of$3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. 9 WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against OMO Science, Energy & Technology Inc., t/a Lubes & Specialty Products, pursuant to the terms of Note Two in the amount of$639,427.94, plus attorneys' fees of$3,456.00, pre judgment interest at the rate of$66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. COUNT VII 39. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-38 of this Complaint as if fully set forth herein. 40. Under the terms and conditions of the Second Stoner Guaranty, Stoner guaranteed to repay all obligations due and owing with respect to Loan Two. Under the terms and conditions of the Second Stoner Guaranty, Stoner authorized any attorney designated by the - Plaintiff to appear on his behalf and to confess judgment against 'him for all sums owed pursuant to Note Two and the Second Stoner Guaranty, and agreed to pay the Plaintiffs attorneys' fees incurred. 41. As of April 15, 2013, there is due and owing to the Plaintiff from Max Stoner under the terms and conditions of Note Two and the Second Stoner Guaranty the total aggregate amount of$642,883.94, consisting of an unpaid principal balance of$561,727.97, accrued and unpaid interest of $1,989.46, other charges of $74,519.83, late charges of $1,193.68 and attorneys' fees of $3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment,post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Max Stoner, pursuant to the terms of Note Two and the Second 10 4 � A Stoner Guaranty, in the amount of$639,427.94, plus attorneys' fees of$3,456.00, pre judgment interest at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. COUNT VIII 42. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-41 of this Complaint as if fully set forth herein. 43. Under the terms and conditions of the Second Riddick Guaranty, Riddick guaranteed to repay all obligations due and owing with respect to Loan Two. . Under the terms and conditions of the Second Riddick Guaranty, Riddick authorized any attorney designated by the Plaintiff to appear on his behalf and to confess judgment against him for all sums owed pursuant to Note Two and the Second Riddick Guaranty, and agreed to pay the Plaintiff's attorneys' fees incurred. 44. As of April 15, 2013, there is due and owing to the Plaintiff from Riddick under the terms and conditions of Note Two and the Second Riddick Guaranty the total aggregate amount of$642,883.94, consisting of an unpaid principal balance of$561,727.97, accrued and unpaid interest of $1,989.46, other charges of $74,519.83, late charges of $1,193.68 and attorneys' fees of $3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment, post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against James Riddick, pursuant to the terms of Note Two and the Second Riddick Guaranty, in the amount of$639,427.94, plus attorneys' fees of$3,456.00,pre judgment 11 G� a interest at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment, post-judgment interest, and costs. COUNT IX 45. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-44 of this Complaint as if fully set forth herein. 46. Under the terms and conditions of the Second Hill Guaranty, Hill guaranteed to repay all obligations due and owing with respect to Loan Two. Under the terms and conditions of the Second Hill Guaranty, Hill authorized any.attorney designated by the Plaintiff to appear on his behalf and to confess judgment against him for all sums owed pursuant to Note Two and the Second Hill Guaranty, and agreed to pay the Plaintiff's attorneys' fees incurred. 47. As of April 15, 2013, there is due and owing.to the Plaintiff from Gerald Hill under the terms and conditions of Note Two and the Second Hill Guaranty the total aggregate amount of$642,883.94, consisting of an unpaid principal balance of$642,883.94, consisting of an unpaid principal balance of $561,727.97, accrued and unpaid interest of $1,989.46, other charges of $74,519.83, late charges of $1,193.68 and attorneys' fees of $3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$66.31 per day after April, 2013, until the date of entry of judgment, post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Gerald Hill, pursuant to the terms of Note Two and the Second Hill Guaranty, in the amount of$639,427.94, plus attorneys' fees of$3,456.00, pre judgment interest at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment, post- judgment interest, and costs. 12 ti COUNT X 48. Plaintiff hereby incorporates by reference each and every allegation contained in paragraphs 1-47 of this Complaint as if fully set forth herein. 49. Under the terms and conditions of the Jamel Guaranty, Jamel guaranteed to repay all obligations due and owing with respect to Loan Two. Under the terms and conditions of the Jamel Guaranty, Jamel authorized any attorney designated by the Plaintiff to appear on its behalf and to confess judgment against it for all sums owed pursuant to Note Two and the Jamel Guaranty, and agreed to pay the Plaintiff s attorneys' fees incurred. 50. As of April 15, 2013, there is due and owing to,the Plaintiff from Jamel Development Co., LLC under the terms and conditions of Note Two and the Jamel Guaranty the total aggregate amount of$642,883.94, consisting of an unpaid principal balance of$561,727.97, accrued and unpaid interesi of$1,989.46, other charges of$74,519.83, late charges of$1;193.68 and blorneys' fees of $3,456.00. Interest continues to accrue on the unpaid principal amount due under Note One at the rate of$66.31 per day after April 15, 2013, until the date of entry of judgment,post judgment interest, and costs. WHEREFORE, Plaintiff, Susquehanna Bank, prays that judgment by confession be entered in its favor against Jamel Development Co., LLC, pursuant to the terms of Note Two and the Jamel Guaranty, in the amount of $639,427.94, plus attorneys' fees of $3,456.00, pre- judgment interest at the rate of $66.31 per day after April 15, 2013, until the date of entry of judgment,post judgment interest, and costs. 13 q 1 ( ^ • \ l Eric S. Schuster FUNK& BOLTON, P.A. 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201-3111 410.659.4983 (telephone) 410.659.7773 (facsimile) Attorneys for Plaintiff, Susquehanna Bank Dated: April 2013 13010.044:154446 14 r AO CIRCUIT COURT FOR BALTIMORE .CITY Frank M. Conaway Clerk of the Circuit Court Courthouse East 111 North Calvert Street Room 462 Baltimore, MD 21202- (410) -333-3722 , TTY for Deaf : (410) -333-4389 06/12/14 Case Number: 24-C-13-002302 CJ Date Filed: 04/19/2013 Status : Closed/Inactive Judge Assigned: To Be Assigned, Location : CTS Start : 04/19/13 Target : 10/16/14 Susquehanna Bank vs OMO Science, Energy & Technology, Inc, et al C A S E H I S T O R Y OTHER REFERENCE NUMBERS Description Number ------------------------------ --------------- Case Folder ID C13002302V0l INVOLVED PARTIES Type Num Name(Last,First,Mid,Title) Addr Str/End Pty. Disp. Entered Addr Update ---------------------------------------------------------------------------------------------------------------------------------- PLT 001 Susquehanna Bank BA CC 05/15/13 04/19/13 Party ID: 4752899 Mail: 1570 Manheim Pike 04/19/13 04/23/13 DG .Lancaster, PA 17604 Attorney: 0000916 Schuster, Eric S Appear: 04/19/2013 04/23/13 Funk & Bolton, P.A. 36 South Charles Street 12th Floor Baltimore, MD 21202-3111 (410)659-4983 DEF 001 OMO Science, Energy & Technology, Inc BA CC 05/15/13 04/19/13 Party ID: 4752900 TRA Lubes & Specialty Products, 04/23/13 24"C-13`002302 Date : 06/12/14 Time : 12 : 05 Page : 2 Mail: 2225 Evergreen Street 04/23/13 04/23/13 DG Baltimore, MD 21210 Attorney: 0801802 Swallow, Bradley J Appear: 04/19/2013 04/23/13 36 South Charles Street 12th Floor Baltimore, MD 21201-3111 (410)659-7700 Type Num Name(Last,First,Mid.Title) Addr Str/End Pty, Disp. Entered Addr Update ---------------------------------------------------------------------------------------------------------------------------------- DEF 002 Stoner, Max BA CC 05/15/13 04/19/13 Party ID: 4752901 Mail: 5041 Woodbox Lane 04/19/13 04/23/13 DG Mechanicsburg, PA 17055 Attorney: 0801802 Swallow, Bradley J Appear: 04/19/2013 04/23/13 36 South Charles Street 12th Floor Baltimore, MD 21201-3111 (410)659-7700 DEF 003 Riddick, James BA CC 05/15/13 04/19/13 Party ID: 4752907 Mail: 110 Hannum Drive 04/19/13 04/23/13 DG Bear, DE 19701 Attorney: 0801802 Swallow, Bradley J Appear: 04/19/2013 04/23/13 36 South Charles Street 12th Floor Baltimore, MD 21201-3111 (410)659-7700 DEF 004 Hill, Gerald BA CC 05/15/13 04/19/13 Party ID: 4752909 Mail: 12307 Valley Hills Drive 04/19/13 04/23/13 DG Houston, TX 77071 Attorney: 0801802 Swallow, Bradley J Appear: 04/19/2013 04/23/13 36 South Charles Street 12th Floor Baltimore, MD 21201-3111 (410)659-7700 DEF 005 Jame] Development Co, LLC BA CC 05/15/13 04/19/13 Party ID: 4752910 Mail: 12715 Buckhardt Court 04/19/13 10/01/13 10/08/13 PMR 04/23/13 DG Clinton, MD 20735 24'-C-11-002302 Date: 06/12/14 Time: 12 : 05 . Page : 3 Mail: 110 Hannum Drive 10/08/13 10/08/13 PMR Bear, DE 19701 Attorney: 0801802 Swallow, Bradley J Appear: 04/19/2013 04/23/13 36 South Charles Street 12th Floor Baltimore, MD 21201-3111 (410)659-7700 DISPOSITION HISTORY Disp Disp Stage Activity Date Code Description Code Description User Date -------- ----- ------------------------------ ----- ------------------------------ ---- -------- 05/15/13 CC Confessed/Consent Judgmnt BA BEFORE ANSWER DG 05/20/13 05/06/13 DC Dismissed by Court BA BEFORE ANSWER DG 05/07/13 JUDGE HISTORY JUDGE ASSIGNED Type Assign Date Removal RSN ------------------------------ ---- ----------- ----------- TBA To Be Assigned, J 04/23/13 DOCUMENT TRACKING Num/Seq Description Filed Entered Party Jdg Ruling Closed User ID -------- ---------------------------------------- -------- -------- ------ --- ------------------ -------- -------- 00001000 Complaint and Judgment by Confession 04/19/13 04/23/13 PLT001 PJW Granted 05/06/13 DG PMR 00001001 Order of Court 05/07/13 05/07/13 000 PJW Moot 05/06/13 DG OG ORDERED that Pltff's Complaint for Judgment by Confession is DISMISSED w/o prejudice & with leave to amend in conformity with Md Rule 2-611(a), White J 00001002 Copies Mailed 05/07/13 05/07/13 000 TBA Moot 05/06/13 DG DG 00002000 Amended Complaint and Confession of 05/09/13 05/09/13 PLT001 PJW Granted 05/15/13 OG DG Judgment and Comparison Copy Attached Amended Affidavit, Amended Entry of Appearance & Amended Proposed Order 00002001 Amended Order of Court 05/20/13 05/20/13 000 'JW Moot 05/15/13 DG DG 00002002 Copies Mailed 05/20/13 05/20/13 000 TBA Moot 05/15/13 DG DG 00003000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 24'C-13-002302 Date : 06/12/14 Time: 12 : 05 Page : 4 Num/Seq Description Filed Entered Party Jdg Ruling Closed User ID 00004000 Confessed Judgment Notice Sent Count I 05/20/13 05/20/13 DEF001 PJW Moot 05/20/13 DG DG 00005000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00006000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF002 PJW Moot 05/20/13 DG DG II 00007000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00008000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF003 PJW Moot 05/20/13 DG DG III 00009000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00010000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF004 PJW Moot 05/20/13 DG DG IV 00011000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00012000 Confessed Judgment Notice Sent Count V 05/20/13 05/20/13 DEF005 PJW Moot 05/20/13 DG DG 00013000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00014000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF001 PJW Moot 05/20/13 DG DG VI 00015000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00016000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF002 PJW Moot 05/20/13 DG. DG VII 00017000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 'JW Moot 05/20/13 DG 00018000 Confessed Judgment Notice Sent - Count 05/20/13 05/20/13 DEF003 PJW Moot 05/20/13 DG DG VIII 00019000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00020000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF004 PJW Moot 05/20/13 DG DG IX 00021000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00022000 Confessed Judgment Notice Sent - Count X 05/20/13 05/20/13 DEF005 PJW Moot 05/20/13 DG DG 00023000 Affidavit of Service - Served 05/28/13 05/30/13 DEF001 TBA Moot 05/30/13 VB VB Notice of Confessed Judgment served 05/24/13 00024000 Return of Service - Served 06/12/13 06/17/13 DEF001 TBA Moot 06/17/13 ASJ ASJ Notice of Confessed Judgment served 06/07/13 e 24-.C-13-002302 Date : 06/12/14 Time : 12 : 05 Page : 15 Num/Seq Description Filed Entered Party Jdg Ruling Closed User ID -------- ---------------------------------------- -------- -------- ------ --- ------------------ -------- -------- 00025000 Return of Service - Served 06/12/13 06/17/13 DEF001 TBA Moot 06/17/13 ASJ ASJ Notice of Confessed Judgment served 06/11/13 00026000 Request For Issuance of Writ of 10/01/13 10/08/13 FLT001 TBA PMR Execution Filed by Attorney: Eric S Schuster Esq 60027000 Writ of Execution 10/08/13 10/08/13 DEF005 TBA Moot 10/08/13 PMR PMR Line with property description with new check 00028000 Line With Property Description 10/17/13 10/22/13 PLT001 TBA Moot 10/22/13 PMR Filed by Attorney: Eric S Schuster Esq 00029000 Writ of Execution 11/22/13 11/25/13 PLT001 TBA BS BS SERVICE Form Name Issued Response Served Returned Agency Notice of Confessed Judgment 05/20/13 Private Process DEF001 OMO Science, Energy & Technology, Notice of Confessed Judgment 05/20/13 06/23/13 05/24/13 Private Process DEF001 OMO Science, Energy & Technology, Notice of Confessed Judgment 05/20/13 07/11/13 06/11/13 Private Process DEF001 OMO Science, Energy & Technology, Notice of Confessed Judgment 05/20/13 07/07/13 06/07/13 Private Process DEF001 OMO Science, Energy & Technology, Notice of Confessed Judgment 05/20/13 Private Process DEF002 Stoner, Max Notice of Confessed Judgment 05/20/13 Private Process DEF002 Stoner, Max Notice of Confessed Judgment 05/20/13 Private Process DEF003 Riddick, James Notice of Confessed Judgment 05/20/13 Private Process DEF003 Riddick, James Notice of Confessed Judgment 05/20/13 Private Process DEF004 Hill, Gerald Notice of Confessed Judgment 05/20/13 Private Process DEF004 Hill, Gerald 24`'-C-13-002302 Date : 06/12/14 Time : 12 : 05 Page : 6 Form Name Issued Response Served Returned Agency ---------------------------------------- -------- -------- -------- -------- ------------------------------ Notice of Confessed Judgment 05/20/13 Private Process DEF005 Jamel Development Co, LLC, Notice of Confessed Judgment 05/20/13 Private Process DEF005 Jamel Development Co. LLC, TICKLE Code Tickle Name Status Expires #Days AutoExpire GoAhead From Type Num Seq ---- -------------------- ------ -------- ----- ---------- ------- ---- ---- ----- --- LSRV 120 Days Lack Of Jur CLOSED 09/23/13 126 no no 2 002 BEGIN JUDGMENT (S) - CASE HISTORY 1 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: OMO Science, Energy & Technology, Inc TRA: Lubes & Specialty Products Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $168,284.88 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $171.740.88 Count I - Post-judgment interest & Costs 2 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Stoner, Max Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $168,284.88 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $171.740.88 Count II: post-judgment interest & costs 24'C`!Y-002302 Date: 06/12/14 Time: 12 : 05 Page : 7 3 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Riddick, James Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $168,284.88 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3.456.00 Total Indexed Judgment: $171,740.88 Count III; post-judgment interest & costs 4 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Hill, Gerald Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $168,284.88 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $171,740.88 Count IV; post-judgment interest & costs 5 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Jame] Development Co, LLC Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $168,284.88 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee; $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $171,740.88 Count V; post-judgment interest & costs 6 MONEY JUDGMENT 24-F'-13'002302 Date : 06/12/14 Time : 12 : 05 Page : 8 ORIGINAL JUDGMENT Judgment Against: OMO Science, Energy & Technology, Inc TRA: Lubes & Specialty Products Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $637,286.56 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $640,742.56 Count VI: post-judgment interest & costs 7 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Stoner, Max Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $637,286.56 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $640,742.56 Count VII; post-judgment interest & costs 8 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Riddick, James Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $637,286.56 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $640,742.56 Count VIII post-judgment interest & costs 24-C—`1.39002302 Date: 06/12/14 Time : 12 : 05 Page : 9 9 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Hill, Gerald Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date:. 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $637,286.56 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3.456.00 Total Indexed Judgment: $640,742.56 Count IX; post-judgment interest & costs 10 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Jamel Development Co, LLC Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 .Judgment Index Date: 05/20/13 Amount of Judgment: $637,286.56 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3.456.00 Total Indexed Judgment: $640,742.56 Count X; post-judgment interest & Costs END JUDGMENT (S) — CASE HISTORY PUBLIC NOTE TITLES 1) ATTEMPT CONTACT 2) forwarded CASE FOLDER HISTORY Date Time Type User Location Clerk Reason ---- ---- ---- - -- -------- ----- ------ 06/26/13 1:00 PM CheckIn Civil Records, Room 409 East OM 06/26/13 9:35 AM Transfer FR1 Room 409 Courthouse East FS 06/26/13 9:27 AM Checkout FS Civil Div. , Room 462 East JH 05/20/13 3:16 PM CheckIn Civil Records, Room 409 East OM 24-=C°1.3`-002302 Date: 06/12/14 Time : 12 : 05 Page : 10 05/20/13 1:04 PM Transfer MH Civil Records, Room 409 East DG Order to be copied & mailed to parties 20 Funk& Bolton, P.A. f � , s IBy Eric S.D. No. 85362uster � E� S ; ou"i i YL VAA 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, * COURT OF COMMON PLEAS Plaintiff, * OF CUMBERLAND COUNTY V. * CIVIL DIVISION MAX STONER * Case No. r ��� G�vy � Defendant. AFFIDAVIT OF ERIC S. SCHUSTER 1, Eric S. Schuster, solemnly affirm under the penalties of perjury that the contents of this Affidavit are true, accurate, and complete to the best of my knowledge, information, and belief. 1. I am counsel for Susquehanna Bank. 2. 1 am competent to be a witness and to testify to the matters and facts stated herein. 3. The last known mailing address of the Judgment Debtor, Max Stoner, is 5041 Woodbox Lane, Mechanicsburg, Pennsylvania 17055. 4. The address of Susquehanna Bank is 1570 Manheim Pike, Lancaster, Pennsylvania 17604. 5. The Judgments which Susquehanna Bank have requested be entered by this Court as Judgments against Defendant, Max Stoner, are valid, enforceable, and unsatisfied. j' Date: 6 By: Eric S. Schuster � nn ACKNOWLEDGMENT STATE OF M &Vv- . ) TO WIT: CITY/COUNTY OF ltvu 0,vandki I HEREBY CERTIFY that, on this P44-day of June, 2014, before me, the subscriber, undersigned Notary Public of the State of Q , personally appeared Eric S. Schuster, known to me (or satisfactorily proven) to Ve the person whose name is subscribed above, and declared and acknowledged under oath, subject to the penalties of perjury, that the matters set forth herein are true, accurate, and complete to the best of his knowledge, information, and belief. IN WITNESS MY Hand and Notarial Seal. CKO-4-e�. C) Notary Publi My Commission Expires: � �S 13010.044:164006 2 CIRCUIT COURT FOR BALTIMORE CITY Frank M. Conaway Clerk of the Circuit Court Courthouse East 111 North Calvert Street Room 462 Baltimore, MD 21202- (410) -333-3722 , TTY for Deaf: (410) -333-4389 06/12/14 Case Number: 24-C-13-002302 CJ Date Filed: 04/19/2013 Status : Closed/Inactive Judge Assigned: To Be Assigned, Location : CTS Start : 04/19/13 Target : 10/16/14 Susquehanna Bank vs OMO Science, Energy & Technology, Inc, et al C A S E H I S T O R Y OTHER REFERENCE NUMBERS Description Number ------------------------------ --------------- Case Folder ID C13002302V01 INVOLVED PARTIES Type Num Ndme(Last,First.Mid,Title) Addr Str/End Pty. Disp. Entered Addr Update ---------------------------------------------------------------------------------------------------------------------------------- PLT 001 Susquehanna Bank BA CC 05/15/13 04/19/13 Party ID: 4752899 Mail: 1570 Manheim Pike 04/19/13 04/23/13 DG Lancaster, PA 17604 Attorney: 0000916 Schuster. Eric S Appear: 04/19/2013 04/23/13 Funk & Bolton, P.A. 36 South Charles Street 12th Floor Baltimore, MD 21202-3111 (410)659-4983 DEF 001 OMO Science, Energy & Technology, Inc BA CC 05/15/13 04/19/13 Party ID: 4752900 TRA Lubes & Specialty Products, 04/23/13 24-C-13-002302 Date : 06/12/14 Time : 12 : 05 Page: 2 Mail: 2225 Evergreen Street 04/23/13 04/23/13 DG Baltimore. MD 21210 Attorney: 0801802 Swallow, Bradley J Appear: 04/19/2013 04/23/13 36 South Charles Street 12th Floor Baltimore. MD 21201-3111 (410)659-7700 Type Num Name(Last,First,Mid,Title) Addr Str/End Pty. Disp. Entered Addr Update ---------------------------------------------------------------------------------------------------------------------------------- DEF 002 Stoner, Max BA CC 05/15/13 04/19/13 Party ID: 4752901 Mail: 5041 Woodbox Lane 04/19/13 04/23/13 DG Mechanicsburg, PA 17055 Attorney: 0801802 Swallow, Bradley J Appear: 04/19/2013 04/23/13 36 South Charles Street 12th Floor Baltimore. MD 21201-3111 (410)659-7700 DEF 003 Riddick, James BA CC 05/15/13 04/19/13 Party ID: 4752907 Mail: 110 Hannum Drive 04/19/13 04/23/13 DG Bear, DE 19701 Attorney: 0801802 Swallow, Bradley J Appear: 04/19/2013 04/23/13 36 South Charles Street 12th Floor Baltimore, MD 21201-3111 (410)659-7700 DEF 004 Hill, Gerald BA CC 05/15/13 04/19/13 Party ID: 4752909 Mail: 12307 Valley Hills Drive 04/19/13 04/23/13 DG Houston, TX 77071 Attorney: 0801802 Swallow, Bradley J Appear: 04/19/2013 04/23/13 36 South Charles Street 12th Floor Baltimore, MD 21201-3111 (410)659-7700 DEF 005 Jame] Development Co. LLC BA CC 05/15/13 04/19/13 Party ID: 4752910 Mail: 12715 Buckhardt Court 04/19/13 10/01/13 10/08/13 PMR 04/23/13 DG Clinton, MD 20735 24-C-13-002302 Date : 06/12/14 Time: 12 : 05 Page : 3 Mail: 110 Hannum Drive 10/08/13 10/08%13 PMR Bear, DE 19701 Attorney: 0801802 Swallow, Bradley J Appear: 04/19/2013 04/23/13 36 South Charles Street 12th Floor Baltimore, MD 21201-3111 (410)659-7700 DISPOSITION HISTORY Disp Disp Stage Activity Date Code Description Code Description User Date -------- ----- ------------------------------ ----- ------------------------------ ---- -------- 05/15/13 CC Confessed/Consent Judgmnt BA BEFORE ANSWER DG 05/20/13 05/06/13 DC Dismissed by Court BA BEFORE ANSWER DG 05/07/13 JUDGE HISTORY JUDGE ASSIGNED Type Assign Date Removal RSN ------------------------------ ---- ----------- ----------- TBA To Be Assigned, J 04/23/13 DOCUMENT TRACKING Num/Seq Description Filed Entered Party Jdg Ruling Closed User ID -------- ---------------------------------------- -------- -------- ------ --- ------------------ -------- -------- 00001000 Complaint and Judgment by Confession 04/19/13 04/23/13 PLT001 PJW Granted 05/06/13 DG PMR 00001001 Order of Court 05/07/13 05/07/13 000 PJW Moot 05/06/13 DG OG ORDERED that Pltff's Complaint for Judgment by Confession is DISMISSED w/o prejudice & with leave to amend in conformity with Md Rule 2-611(a), White J 00001002 Copies Mailed 05/07/13 05/07/13 000 TBA Moot 05/06/13 DG DG 00002000 Amended Complaint and Confession of 05/09/13 05/09/13 PLT001 PJW Granted 05/15/13 DG DG Judgment and Comparison Copy Attached Amended Affidavit, Amended Entry of Appearance & Amended Proposed Order 00002001 Amended Order of Court 05/20/13 05/20/13 000 PJW Moot 05/15/13 DG OG 00002002 Copies Mailed 05/20/13 05/20/13 000 TBA Moot 05/15/13 DG DG 00003000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 24-C-13-002302 Date : 06/12/14 Time : 12 : 05 Page : 4 Num/Seq Description Filed Entered Party Jdg Ruling Closed User ID -------- ---------------------------------------- -------- -------- ------ --- ------------------ -------- --=----- 00004000 Confessed Judgment Notice Sent - Count I 05/20/13 05/20/13 DEF001 PJW Moot 05/20/13 DG DG 00005000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00006000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF002 PJW Moot 05/20/13 DG DG II 00007000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00008000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF003 PJW Moot 05/20/13 DG DG III 00009000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00010000 Confessed Judgment Notice Sent - Count 05/20/13 05/20/13 DEF004 PJW Moot 05/20/13 DG DG IV 00011000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00012000 Confessed Judgment Notice Sent Count V 05/20/13 05/20/13 DEF005 PJW Moot 05/20/13 DG DG 00013000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00014000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF001 PJW Moot 05/20/13 DG DG VI 00015000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00016000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF002 PJW Moot 05/20/13 DG DG VII 00017000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00018000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF003 PJW Moot 05/20/13 DG DG VIII 00019000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00020000 Confessed Judgment Notice Sent Count 05/20/13 05/20/13 DEF004 PJW Moot 05/20/13 DG DG IX 00021000 Judgment Indexed on 05/20/13 05/20/13 05/20/13 000 PJW Moot 05/20/13 DG 00022000 Confessed Judgment Notice Sent Count X 05/20/13 05/20/13 DEF005 PJW Moot 05/20/13 DG DG 00023000 Affidavit of Service - Served 05/28/13 05/30/13 DEF001 TBA Moot 05/30/13 VB VB Notice of Confessed Judgment served 05/24/13 00024000 Return of Service - Served 06/12/13 06/17/13 DEF001 TBA Moot 06/17/13 ASJ ASJ Notice of Confessed Judgment served 06/07/13 24-C-13-002302 Date: 06/12/14 Time: 12 : 05 Page : 5 Num/Seq Description Filed Entered Party Jdg Ruling Closed User ID -------- ---------------------------------------- -------- -------- ------ --- ------------------ -------- -------- 00025000 Return of Service - Served 06/12/13 06/17/13 DEF001 TBA Moot 06/17/13 ASJ ASJ Notice of Confessed Judgment served 06/11/13 00026000 Request For Issuance of Writ of 10/01/13 10/08/13 PLT001 TBA PMR Execution Filed by Attorney: Eric S Schuster Esq 00027000 Writ of Execution 10/08/13 10/08/13 DEF005 TBA Moot 10/08/13 PMR PMR Line with property description with new check 00028000 Line With Property Description 10/17/13 10/22/13 PLT001 TBA Moot 10/22/13 PMR Filed by Attorney: Eric S Schuster Esq 00029000 Writ of Execution 11/22/13 11/25/13 PLT001 TBA BS BS SERVICE Form Name Issued ' Response Served Returned Agency ---------------------------------------- -------- -------- -------- -------- ------------------------------ Notice of Confessed Judgment 05/20/13 Private Process DEF001 OMO Science, Energy & Technology, Notice of Confessed Judgment 05/20/13 06/23/13 05/24/13 Private Process DEF001 OMO Science, Energy & Technology, Notice of Confessed Judgment 05/20/13 07/11/13 06/11/13 Private Process DEF001 OMO Science, Energy & Technology, Notice of Confessed Judgment 05/20/13 07/07/13 06/07/13 Private Process DEF001 OMO Science, Energy & Technology, Notice of Confessed Judgment 05/20/13 Private Process DEF002 Stoner, Max Notice of Confessed Judgment 05/20/13 Private Process DEF002 Stoner, Max Notice of Confessed Judgment 05/20/13 Private Process DEF003 Riddick, James Notice of Confessed Judgment 05/20/13 Private Process DEF003 Riddick. James Notice of Confessed Judgment 05/20/13 Private Process DEF004 Hill. Gerald Notice of Confessed Judgment 05/20/13 Private Process DEF004 Hill, Gerald 24-C-13-002302 Date : 06/12/14 Time : 12 : 05 Page : 6 Form Name Issued Response Served Returned Agency ---------------------------------------- -------- -------- -------- -------- ------------------------------ Notice of Confessed Judgment 05/20/13 Private Process DEF005 Jame] Development Co, LLC, Notice of Confessed Judgment 05/20/13 Private Process DEF005 Jamel Development Co, LLC, TICKLE Code Tickle Name Status Expires Rays AutoExpire GoAhead From Type Num Seq ---- -------------------- ------ -------- ----- ---------- ------- ---- ---- ----- --- LSRU 120 Days Lack Of Jur CLOSED 09/23/13 126 no no 2 002 BEGIN JUDGMENT (S) — CASE HISTORY 1 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: OMO Science, Energy & Technology. Inc TRA: Lubes & Specialty Products Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $168,284.88 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3.456.00 Total Indexed Judgment: $171.740.88 Count I - Post-judgment interest & Costs 2 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Stoner, Max Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $168,284.88 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $171.740.88 Count II: post-judgment interest & costs 24-C-13-002302 Date: 06/12/14 Time : 12 : 05 . Page : 7 3 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Riddick, James Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20%13 Amount of Judgment: $168,284.88 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $171,740.88 Count III; post-judgment interest & costs s 4 MONEY JUDGMENT ORIGINAL JUDGMENT judgment Against: Hill, Gerald Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $168.284.88 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $:00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $171,740.88 Count IV: post-judgment interest & costs 5 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Jamel Development Co, LLC Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $168.284.88 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3.456.00 Total Indexed Judgment: $171,740.88 Count V: post-judgment interest & costs 6 MONEY JUDGMENT D 24—C-13-002302 Date : 06/12/14 Time : 12 : 05 Page : 8 ORIGINAL JUDGMENT Judgment Against: OMO Science, Energy & Technology, Inc TRA: Lubes & Specialty Products Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $637,286.56 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $640,742.56 Count VI: post-judgment interest & costs 7 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Stoner, Max Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $637,286.56 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3.456.00 Total Indexed Judgment: $640.742.56 Count VII: post-judgment interest & costs 8 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Riddick, James Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $637,286.56 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $640.742.56 Count VIII post-judgment interest & costs 24-C-13-002302 Date : 06/12/14 Time : 12 : 05 Page: 9 9 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Hill, Gerald Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $637,286.56 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $640.742.56 Count IX: post-judgment interest & costs 10 MONEY JUDGMENT ORIGINAL JUDGMENT Judgment Against: Jame] Development Co, LLC Judgment in Favor of: Susquehanna Bank, Judgment Ordered Date: 05/15/13 Judgment Entry Date: 05/20/13 Judgment Index Date: 05/20/13 Amount of Judgment: $637,286.56 Other Fee: $.00 PreJudgment Interest: $.00 Service Fee: $.00 Appearance Fee: $.00 Witness Fee: $.00 Filing Fee: $.00 Attorney Fee: $3,456.00 Total Indexed Judgment: $640,742.56 Count X: post-judgment interest & Costs END JUDGMENT (S) — CASE HISTORY PUBLIC NOTE TITLES 1) ATTEMPT CONTACT 2) forwarded CASE FOLDER HISTORY Date Time Type User Location Clerk Reason ---- ---- ---- ---- -------- ----- ------ 06/26/13 1:00 PM CheckIn Civil Records, Room 409 East OM 06/26/13 9:35 AM Transfer FR1 Room 409 Courthouse East FS 06/26/13 9:27 AM CheckOut FS Civil Div. , Room 462 East JH 05/20/13 3:16 PM CheckIn Civil Records, Room 409 East OM 24-C-13-002302 Date : 06/12/14 Time: 12 : 05 Page : 10 05/20/13 1:04 PM Transfer MH Civil Records, Room .409 East DG Order to be copied & mailed to parties Y, Frank Y. Conaway, Clerk of the Circuit Court for Baltimore City, hereby certify that this is a true copy from the record in this court. Witness the hand and act of the undersigned this I day off--"Ty� 24, ll Circuit COurt for BalUmore City, Maryland - N - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL JUDGMENT CERTIFICATE OF RESIDENCE OF JUDGMENT CREDITOR It is hereby certified that the precise residence address of the judgment creditor and defendant, in the above entitled judgment, is: Plaintiff: Susquehanna Bank 1570 Manheim Pike Lancaster,Pennsylvania 17604 VS. Defendant: Max Stoner 5041 Woodbox Lane Mechanicsburg Pennsylvania 17055 Date: C Attorney for Judgment Creditor/Creditor NOTICE OF THE ENTRY OF JUDGMENT AGAINST THE DEFENDANT(S)WAS GIVEN BY ORDINARY MAIL TO THE DEFENDANT(S)TOGETHER WITH A COPY OF ALL DOCUMENTS FILED IN SUPPORT THEREOF. PROTHONOTARY Of Cumberland County David D. Buell 1 Courthouse Square, Suite 100 Carlisle, Pennsylvania 17013 717-240-6195 No. Date: Susquehanna Bank , PLAINTIFF Vs. Max Stoner , DEFENDANT NOTICE TO: 5041 Woodbox Lane (Defendant's address) Mechanicsburg Pennsylvania 17055 Pursuant to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on (a&2 ,2014 a Judgment,was entered against you in this office in the proceeding as indlcated above. Deputy Prothonotary Date mailed: 13010.044:164013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Susquehanna Bank VS. Max Stoner Plaintiff Defendant Address: GARNISHEE: ORRSTOWN BANK 1000 Bryn Mawr Road Carlisle, Pennsylvania 17013 •❑ Confessed Judgment TO THE PROTHONOTARY OF THE SAID COURT: ❑✓ Other File No. 14-3690 Amount Due $812,483.44 Interest (plus post -judgment intere Atty's Comm N/A Costs N/A The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). 0 (Indicate) Index this writ against the garnishee (s) as a lis pendens against realtat the 1 defe dant(s) described in the attached exhibit. Date 0 I Signature: Print Name: Address: f.:25,06 tair r 33,5-o dos -h 8F c 61,515 lot Ji Attorney for: Telephone: Supreme Court ID No: 85362 Eric S. Schuster 36 S. Charles St., 12th Floor Baltimore, Maryland 21201 Susquehanna Bank 410-659-4983 Co tr, SO au�LL THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square• Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net Susquehanna Bank Vs. NO 14-3690 Civil Term CIVIL ACTION — LAW Max Stoner WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against Max Stoner, Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of Orrstown Bank, 1000 Bryn Mawr Road, Carlisle, PA 17013 GARNISHEE(S), as garnishee, Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $812,483.44 Plaintiff Paid Interest (PLUS POST -JUDGMENT INTEREST) Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid t b--50 Other Costs Date: 10/10/14 /S/ Q- .+ w_1/ David D. Buell, Prothonotary By: REQUESTING PARTY: Name : Eric S. Schuster, Esq. Address: Funk & Bolton, 36 S. Charles St., 12`h Floor Baltimore, MD 21201 Attorney for: Plaintiff Telephone: 410-659-4983 Supreme Court ID No. 85362 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION 0 Confessed Judgment Susquehanna Bank Max Stoner Plaintiff : ID Other VS. File No. 14-3690 Amount Due $812,483.44 Address: GARNISHEE: Wells Fargo Bank, N.A. 604 E. High Street Carlisle Pennsylvania 17013 Defendant Interest (plus post -judgment intere Atty's Comm N/A Costs N/A TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). Date (Indicate) Index this writ against the garnishee (s) as a lis pe 1 c Sete ant s) escribe in the attached exhibit. Signature: Print Name: Address: 3 r le" 314-141° 133,9 05+3 Fr 6.--0 pet ei',#)/ Attorney for: Telephone: ens against real tate c.,$) Eric S. Schuster 36 S. Charles St., 12th Floor Baltimore, Maryland 21201 Susquehanna Bank 410-659-4983 Supreme Court ID No: 85362 ) Co THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net Susquehanna Bank Vs. NO 14-3690 Civil Term CIVIL ACTION — LAW Max Stoner WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against Max Stoner, Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of Wells Fargo Bank, N. A., 604 E. High Street, Carlisle, PA 17013 GARNISHEE(S), as garnishee, Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $812,483.44 Plaintiff Paid Interest (PLUS POST -JUDGMENT INTEREST) Law Library Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $62.50 Other Costs Date: 10/10/14 /5( Dae, dl /o.c David D. Buell, Prothonotary By: /e X Deputy REQUESTING PARTY: Name : Eric S. Schuster, Esq. Address: Funk & Bolton, 36 S. Charles St., 12`h Floor, Baltimore, MD 21201 Attorney for: Plaintiff Telephone: 410-659-4983 Supreme Court ID No. 85362 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and alined forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Confessed Judgment Susquehanna Bank VS. Max Stoner Plaintiff ❑✓ Other File No. 14`3690 Amount Due $812,483.44 Defendant Interest (plus post -judgment inter Address: GARNISHEE: BELCO COMMUNITY CREDIT UNION 4015 Paxton Street Harrisburg, Pennsylvania 17111 Atty's Comm NIA Costs N/A TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). Date 0 (Indicate) Index this writ against the garnishee (s) as a lis penden ainst real estate o e dpfe s) d scrib d 'n the attached exhibit. Signature: 111 Print Name: Address: 1 f°�`o© /11vel ,e -it 3 !d• 1 `l r S33,53 Go 4eF t & Lc() et ail Attorney for: Telephone: Supreme Court (C� Eric S. Schuster 36 S. Charles St., 12th Floor Baltimore, Maryland 21201 Susquehanna Bank 410-659-4983 ID No: 85362 Co. ,;111 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717)240-6195 www.ccpa.net Susquehanna Bank Vs. NO 14-3690 Civil. Term CIVIL ACTION — LAW Max Stoner WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against Max Stoner, Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of Belco Community Credit Union, 4015 Paxton Street, Harrisburg, PA' 17111 GARNISHEE(S), as garnishee, Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. (Specifically describe property) and to notify the garnishee.that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s)• with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being, funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $812,483.44 Plaintiff Paid Interest (PLUS POST -JUDGMENT INTEREST) Law Library Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $62.50 Other Costs Date: 10/10/14 /11 Pc,oioc . / al David D. Buell, Prothonotary By: 4b* K- Xlie 94 Deputy REQUESTING PARTY: Name : Eric S. Schuster, Esq. Address: Funk & Bolton, 36 S. Charles St., 12th Floor, Baltimore, MD 21201 Attorney for: Plaintiff Telephone: 410-659-4983 Supreme Court ID No. 85362 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Susquehanna Bank VS. Max Stoner CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Confessed Judgment Plaintiff Q✓ Other File No. 14-3690 Amount Due $812,483.44 zc Defendant Interest (plus post -judgment inter } ca Atty's Comm N/A Costs N/A Address: GARNISHEE: UBS Financial Services Inc. 101 West Elm Street, Suite 200 Conshohocken, Pennsylvania 19428 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). 0 (Indicate) Index this writ against the garnishee (s) as a lis pendens against real e of the defennt s de c'n the attached exhibit. Date (Q 7 ' cribed Signature: 1 C Print Name: Address: Attorney for: Telephone: Supreme Court ID No: 85362 ric S. Schuster 36 S. Charles St., 12th Floor Baltimore, Maryland 21201 Susquehanna Bank 410-659-4983 �� 6-e 6. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net Susquehanna Bank Vs. NO 14-3690 Civil Term CIVIL ACTION — LAW Max Stoner WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against Max Stoner, Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of UBS Financial Services, Inc., 101 West Elm Street, Suite 200, Conshohocken, PA 19428 GARNISHEE(S), as garnishee, Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $812,483.44 Plaintiff Paid Interest (PLUS POST -JUDGMENT INTEREST) Law Library Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $62.50 Other Costs Date: 10/10/14 >51 )an;' David D. Buell, Prothonotary By: REQUESTING PARTY: Name : Eric S. Schuster, Esq. Address: Funk & Bolton, 36 S. Charles St., 12th Floor, Baltimore, MD 21201 Attorney for: Plaintiff • Telephone: 410-659-4983 Supreme Court ID No. 85362 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Susquehanna Bank vs. Max Stoner Plaintiff Defendant Address: GARNISHEE: PNC BANK 105 Noble Boulevard Carlisle, Pennsylvania 17013 •❑ Confessed Judgment TO THE PROTHONOTARY OF THE SAID COURT: ❑✓ Other File No. 14-3690 Amount Due $812,483.44 Interest (plus post -judgment int Atty's Comm N/A Costs N/A 0 C) -4 O The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). 0 (Indicate) Index this writ against the garnishee (s) as a lis pendens against re.,es : ; of the Date defenditn s) escribpd in the attached exhibit. (�, � P{ (33, S6 cos/ `FP sto 1.5-6/01,` Signature: t �> Print Name: Eric S. Schuster Address: Attorney for: Telephone: 36 S. Charles St., 12th Floor Baltimore, Maryland 21201 Susquehanna Bank 410-659-4983 Supreme Court ID No: 85362 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net Susquehanna Bank Vs. NO 14-3690 Civil Term CIVIL ACTION — LAW Max Stoner WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against Max Stoner, Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of PNC Bank, 105 Noble Boulevard, Carlisle, PA 17013 GARNISHEE(S), as garnishee, Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $812,483.44 Plaintiff Paid Interest (PLUS POST -JUDGMENT INTEREST) Law Library Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $62.50 Other Costs Date: 10/10/14 REQUESTING PARTY: Name : Eric S. Schuster, Esq. Address: Funk & Bolton, 36 S. Charles St., 12th Floor, Baltimore, MD 21201 /57 Oeuke,;i David D. Buell, Prothonotary By: Attorney for: Plaintiff Telephone: 410-659-4983 Supreme Court ID No. 85362 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law TRUE COPY FROM RECORD In Testimony whereof, 1 here unto set my hand. ' and the se I of said C. sle, Pa. • This day19 rothonotary 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION • Confessed Judgment A-t%cacot Susquehanna Bank Max Stoner Plaintiff •✓0 Other VS. File No. 14-3690 Amount Due $812,483.44 Defendant Address: GARNISHEE: UBS Financial Services Inc. 101 West Elm Street, Suite 200 Conshohocken, Pennsylvania 19428 Interest Atty's Comm N/A Costs N/A C"D c -off m m u,r v `3 (plus post -judgment inte) TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Montgomery County, for debt, interest and costs, upon the following described property of the defendant (s) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Montgomery County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from Garnishee to Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). Date ❑ (Indicate) Index this writ against the garnishee (s) as a lis defen ant(s) d scribed in the attached exhibit. Signature: Print Name: Address: Attorney for: Telephone: Supreme Court ID No: 85362 pendens against real estate of , -he Eric S. Schuster 36 S. Charles St., 12th Floor Baltimore, Maryland 21201 Susquehanna Bank 410-659-4983 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net Susquehanna Bank Vs. NO 14-3690 Civil Term CIVIL ACTION — LAW Max Stoner M o A4 WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF r:"••: '1 COUNTY: To satisfy the judgment, interest and costs against Max Stoner, Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of UBS Financial Services, Inc., 101 West Elm Street, Suite 200, Conshohocken, PA 19428 GARNISHEE(S), as garnishee, Any and all funds, monies, credits, deposits, accounts, certificates or other assets payable from - Garnishee to Defendant. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $812,483.44 Plaintiff Paid Interest (PLUS POST -JUDGMENT INTEREST) Law Library Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $62.50 Other Costs Date: 10/10/14 is/ -4.4_01,09 David D. Buell, Prothonotary By: REQUESTING PARTY: Name : Eric S. Schuster, Esq. Address: Funk & Bolton, 36 S. Charles St., 12th Floor, Baltimore, MD 21201 Attorney for: Plaintiff Telephone: 410-659-4983 Supreme Court ID No. 85362 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY H P R -� �' I R'Y of C;:t���tie��y�,d � t iIl � f P G I / ; i'C 2014 OCT 23 AM 9: 117 OFF. OF THE k!t.F IF CUMBERLAND COUNT' PENNSYLVANIA Susquehanna Bank vs. Max Stoner Case Number 2014-3690 SHERIFF'S RETURN OF SERVICE 10/17/2014 09:27 AM - Jamie DiMartile, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Wells Fargo, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Jennifer Hommerbocker, Service Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. A E DIMARTILE, DEPUTY SO ANSWERS, October 20, 2014 RONNS' R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teieosoft, b'c. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF THE $14,MIFF ED -OFFICE Cyr THE PROTHONOTARY 20I4 OCT 23 AM -9 4 7 CUMBERLAND COUNTY PENNSYLVANIA Susquehanna Bank vs. Max Stoner Case Number 2014-3690 SHERIFF'S RETURN OF SERVICE 10/17/2014 09:33 AM - Jamie DiMartile, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Orrstown Bank, 22 South Hanover Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Chastity Bucher, Head Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. IE DIMARTILE, DEPUTY SO ANSWERS, October 20, 2014 RONNY R ANDERSON, SHERIFF (C) CountyS.uite Sheriff, Teleosoft, inc. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY HE �4G OFFICE PIR 2014 4CT 23 AM 9: 4 7 CUPENNSYLVANIA BFRLAND CO NNS YLVq NIUNT Y Susquehanna Bank vs. Max Stoner Case Number 2014-3690 SHERIFF'S RETURN OF SERVICE 10/17/2014 09:40 AM - Jamie DiMartile, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Wendy Whistler, Teller Banking Supervisor, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. October 20, 2014 (c) CountySute Sheriff, Teleosoft, = c. IE DIMARTILE, DEPUTY SO ANSWERS, RONO R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FIED-oFFIcciiiptoppi THE PROTH 1'tH:J�TAi l 2014 QCT 23 01 914 7 CUMBERLAND COUNTY � F PENNSYLVANIA a.RIF Susquehanna Bank vs. Max Stoner Case Number 2014-3690 SHERIFF'S RETURN OF SERVICE 10/17/2014 10:44 AM - Jamie DiMartile, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, BELCO Community Credit Union, 5304 Carlisle Pike, Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Ashley Perry, Head Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on October 20, 2014 to Max Stoner at 317 Woodland AVenue, Mechanicsburg, PA 17055. IE DIMARTILE, DEPUTY SO ANSWERS, October 20, 2014 RONR ANDERSON, SHERIFF (c} CountySuiie Sheriff, Tcleosoti, inc. Funk & Bolton, P.A. By Eric S. Schuster I.D. No. 85362 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) R l C , r J 09 Cti '' 3t.;.t _1 ) COU; ► Y r VS J Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, * COURT OF COMMON PLEAS Plaintiff, * OF CUMBERLAND COUNTY v. * CIVIL DIVISION MAX STONER * Case No. 14-3690 Defendant, * * v. BELCO COMMUNITY CREDIT UNION Garnishee. * PRAECIPE FOR ENTRY OF JUDGMENT AGAINST GARNISHEE BELCO COMMUNITY CREDIT UNION To: Prothonotary of Cumberland County Kindly enter a judgment in favor of the Plaintiff, Susquehanna Bank, and against the Garnishee, Belco Community Credit Union, in the amount of $7,566.04 on admissions contained in Garnishee's Answers to Interrogatories, a copy of which is attached hereto as Exhibit A. FUNK & BOLTON, P.A. By: Eric S. Schuster, Esquire Attorneys for Plaintiff 0_„,Jska60 eu/61b No ��e Wat lPd2#3ia�37 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which the defendant held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 5. At the time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? '( 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the amount of funds in each account, and the entity electronically depositing those funds on a recurring bas 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. 2 Date: October , 2014 13010.044:166977 Respectfully submitted, Eric S. Schuster I.D. No. 85362 FUNK & BOLTON, P.A. Twelfth Floor 36 South Charles Street Baltimore, Maryland 21201-3111 410.659.4983 (telephone) 410.659.7773 (facsimile) Attorneys for Plaintiff, Susquehanna Bank Funk & Bolton, P.A. By Eric S. Schuster I.D. No. 85362 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, * COURT OF COMMON PLEAS Plaintiff, * OF CUMBERLAND COUNTY v. * CIVIL DIVISION MAX STONER * Case No. 14-3690 Defendant, * * v. BELCO COMMUNITY CREDIT UNION Garnishee. * CERTIFICATE OF SERVICE Eric S. Schuster, Esquire, attorney for the Plaintiff, verifies that a true and correct copy of the Praecipe for Entry of Judgment against Garnishee Belco Community Credit Union, has been mailed to each of the following entities: Belco Community Credit Union 5304 Carlisle Pike Hampden Township Mechanicsburg, Pennsylvania 17055 Max Stoner 5041 Woodbox Lane Mechanicsburg, Pennsylvania 17055 day of October, 2014. via U.S. Mail — First Class Delivery, postage prepaid on this He understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. FUNK & BOLTON, P.A. By: Eric S. Schuster, Esquire Attorneys for Plaintiff Funk & Bolton, P.A. By Eric S. Schuster I.D. No. 85362 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, Plaintiff, v. MAX STONER Defendant, v. BELCO COMMUNITY CREDIT UNION* Garnishee. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Case No. 14-3690 CERTIFICATE OF ADDRESSES I, Eric S. Schuster, Esquire, hereby certify that the names and addresses of the judgment creditor, the judgment debtor, and the garnishee in the above -captioned case are as follows: Plaintiff: Susquehanna Bank Attn: Brian Braungard 1570 Manheim Pike Lancaster, Pennsylvania 17604 Defendant: Max Stoner 5041 Woodbox Lane Mechanicsburg, Pennsylvania 17055 Garnishee: Belco Community Credit Union 5304 Carlisle Pike Hampden Township Mechanicsburg, Pennsylvania 17055 I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. FUNK & BOLTON, P.A. By: 1 r Eric S. Schuster, Esquire - Attorneys for Plaintiff Funk & Bolton, P.A. By Eric S. Schuster I.D. No. 85362 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, * COURT OF COMMON PLEAS Plaintiff, * OF CUMBERLAND COUNTY v. * CIVIL DIVISION MAX STONER * Case No. 14-3690 Defendant, * v. BELCO COMMUNITY CREDIT UNION* Garnishee. (X) (X) NOTICE Notice is hereby given that a Judgment in the above -captioned proceeding has been entered against Belco Community Credit Union, Garnishee in the amount of $7,566.04. A copy of all documents filed with the Prothonotary of Cumberland County in support of the within judgment is/are enclosed. PROTHON ! TARY OF CUMBERLA By: t If you have any questions regarding this Notice, please contact the filing party: Eric S. Schuster, Esquire Funk & Bolton, P.A. 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201-3111 410.659.4983 (This Notice is given in accordance with Pa.R.C.P. No. 236.) NOTICE SENT TO: Belco Community Credit Union 5304 Carlisle Pike Hampden Township Mechanicsburg, Pennsylvania 17055 Max Stoner 5041 Woodbox Lane Mechanicsburg, Pennsylvania 17055 Susquehanna Bank c/o Eric S. Schuster, Esquire Funk & Bolton, P.A. 36 S. Charles Street, 12th Floor Baltimore, Maryland 21201 13010.044:167676 SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee SUSQUEHANNA BANK vs. MAX STONER : NO. 14-3690 and WELLS FARGO BANK, N.A., GARNISHEE ENTRY OF APPEARANCE Pr : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND TO THE PROTHONOTARY: Kindly enter my appearance on behalf Wells Fargo Bank, N.A., Garnishee in the above -captioned matter. Date: \-\\)\ Funk & Bolton, P.A. By Eric S. Schuster I.D. No. 85362 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, * COURT OF COMMON PLEAS Plaintiff, * OF CUMBERLAND COUNTY v. * CIVIL DIVISION MAX STONER * Case No. 14-3690 Defendant. INTERROGATORIES TO GARNISHEE To: UBS Financial Services Inc. 101 West Elm Street Conshohocken, Pennsylvania 19428 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? IV ©. 2. At the time you were served or at any subsequent time was there in your possession custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? Lae,fet yaD,� (,2dot ez.2 :,c.7/-iVe - 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which the defendant /00. held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? /ex' 5. At the time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? kj0 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? 10 a 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. ,)0 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. 5frAkt-/- c:19, ,L6 (s...5z-c-eJec-r- 1-14e-10,47 Leet /2.,1:° 2 Date: October L, 2014 13010.044:166978 Respectfully submitted, t C Eric S. Schuster I.D. No. 85362 FUNK & BOLTON, P.A. Twelfth Floor 36 South Charles Street Baltimore, Maryland 21201-3111 410.659.4983 (telephone) 410.659.7773 (facsimile) Attorneys for Plaintiff, Susquehanna Bank 3 Funk & Bolton, P.A. By Eric S. Schuster I.D. No. 85362 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, * COURT OF COMMON PLEAS Plaintiff, * OF CUMBERLAND COUNTY v. * CIVIL DIVISION MAX STONER * Case No. 14-3690 Defendant, v. UBS FINANCIAL SERVICES, INC. Garnishee. PRAECIPE FOR ENTRY OF JUDGMENT AGAINST GARNISHEE UBS FINANCIAL SERVICES, INC. To: Prothonotary of Cumberland County Kindly enter a judgment in favor of the Plaintiff, Susquehanna Bank, and against the Garnishee, UBS Financial Services, Inc., in the amount of $6,012.81 on admissions contained in Garnishee's Answers to Interrogatories, a copy of which is attached hereto as Exhibit A. FUNK & BOLTON, P.A. By: c._. Eric S. Schuster, Esquire Attorneys for Plaintiff y V0�1 (C /2b,W OJA,+ Ito ,-sDFpA CJLCL4 �,� 157d� R1-1- ?I9 a �i EXHIBIT A I\ Funk & Bolton, P.A. By Eric S. Schuster I.D. No. 85362 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, * COURT OF COMMON PLEAS Plaintiff, * OF CUMBERLAND COUNTY v. * CIVIL DIVISION MAX STONER * Case No. 14-3690 Defendant. * INTERROGATORIES TO GARNISHEE To: UBS Financial Services Inc. 101 West Elm Street Conshohocken, Pennsylvania 19428 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? IU O. 2. At the time you were served or at any subsequent time was there in your possession custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? (tel -i 4e ", yae , �� 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which the defendant held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? g -C 5. At the time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? ° 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? t) 0 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. 5)evii.-/- (2..eeettdci-7 eu 64- /#--- izexexegr amr/ sfre„, 042_ , .6e -A-46 Cf—r re 4 -144/6€.7- r -i -e -(-7V41-70.4)) L." ,2.-/41D 2 Date: October 1 , 2014 13010.044:166978 Respectfully submitted, 1CI Eric S. Schuster I.D. No. 85362 FUNK & BOLTON, P.A. Twelfth Floor 36 South Charles Street Baltimore, Maryland 21201-3111 410.659.4983 (telephone) 410.659.7773 (facsimile) Attorneys for Plaintiff, Susquehanna Bank Funk & Bolton, P.A. By Eric S. Schuster I.D. No. 85362 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank r'S ffff P c. SUSQUEHANNA BANK, Plaintiff, v. MAX STONER Defendant, v. UBS FINANCIAL SERVICES, INC. Garnishee. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Case No. 14-3690 CERTIFICATE OF ADDRESSES I, Eric S. Schuster, Esquire, hereby certify that the names and addresses of the judgment creditor, the judgment debtor, and the garnishee in the above -captioned case are as follows: Plaintiff: Susquehanna Bank Attn: Brian Braungard 1570 Manheim Pike Lancaster, Pennsylvania 17604 Defendant: Max Stoner 5041 Woodbox Lane Mechanicsburg, Pennsylvania 17055 Garnishee: UBS Financial Services, Inc. 1000 Harbor Boulevard, 8th Floor Weehawken, New Jersey 07086 Attn: Alexandra McLnerney I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. FUNK & BOLTON, P.A. By: e Eric S. Schuster, Esquire Attorneys for Plaintiff Funk & Bolton, P.A. By Eric S. Schuster I.D. No. 85362 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, * COURT OF COMMON PLEAS Plaintiff, * OF CUMBERLAND COUNTY v. * CIVIL DIVISION MAX STONER * Case No. 14-3690 Defendant, v. UBS FINANCIAL SERVICES, INC. * Garnishee. (X) (X) NOTICE Notice is hereby given that a Judgment in the above -captioned proceeding has been entered against UBS Financial Services, Inc., Garnishee in the amount of $6,012.81. A copy of all documents filed with the Prothonotary of Cumberland County in support of the within judgment is/are enclosed. PROTHONRY CUMBERLAN r. COU By: If you have any questions regarding this Notice, please contact the filing party: Eric S. Schuster, Esquire Funk & Bolton, P.A. 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201-3111 410.659.4983 (This Notice is given in accordance with Pa.R.C.P. No. 236.) NOTICE SENT TO: UBS Financial Services, Inc. 1000 Harbor Boulevard, 8th Floor Weehawken, New Jersey 07086 Attn: Alexandra McLnerney Max Stoner 5041 Woodbox Lane Mechanicsburg, Pennsylvania 17055 Susquehanna Bank c/o Eric S. Schuster, Esquire Funk & Bolton, P.A. 36 S. Charles Street, 12th Floor Baltimore, Maryland 21201 13010.044:167676 Funk & Bolton, P.A. By Eric S. Schuster I.D. No. 85362 36 South Charles Street, Twelfth Floor Baltimore, Maryland 21201 410.659.4983 (telephone) Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK, * COURT OF COMMON PLEAS Plaintiff, * OF CUMBERLAND COUNTY v. * CIVIL DIVISION MAX STONER * Case No. 14-3690 Defendant, * v. * UBS FINANCIAL SERVICES, INC. * Garnishee. CERTIFICATE OF SERVICE Eric S. Schuster, Esquire, attorney for the Plaintiff, verifies that a true and correct copy of the Praecipe for Entry of Judgment against Garnishee UBS Financial Services, Inc., has been mailed to each of the following entities: UBS Financial Services, Inc. 1000 Harbor Boulevard, 8`" Floor Weehawken, New Jersey 07086 Attn: Alexandra McLnerney Max Stoner 5041 Woodbox Lane Mechanicsburg, Pennsylvania j 7055 via U.S. Mail — First Class Delivery, postage prepaid on this day of October, 2014. He understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. FUNK & BOLTON, P.A. By: c Eric S. Schuster, Esquire Attorneys for Plaintiff SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee SUSQUEHANNA BANK vs. MAX STONER and : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND : NO. 14-3690 WELLS FARGO BANK N.A., GARNISHEE ANSWERS TO INTERROGATORIES IN ATTACHMENT TO: SUSQUEHANNA BANK , Plaintiff 1.- 6. Wells Fargo Bank N.A. holds no assets of and owes no debt to the Judgment Debtor herein. Dated: Al 1111\ JON SI ' IN Atto ey for arnishee Wells Fargo Bank, N.A. Liens, Levies & Garnishments 101 N. Independence Mall East MAC Code# Y1372-039 Philadelphia, PA 19106 VERIFICATION Diana Nazario, being duly sworn according to law, deposes and says that she is the Legal Order Processing Associate of Wells Fargo Bank, NA Garnishee herein, and verifies that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to sworn falsification to authorities. Diana Nazario Legal Order Processing Associate Case: 102372014 Date: 10/30/2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA t✓ Susquehanna Bank CIVIL DIVISION —11 PRAECIPE FOR WRIT OF EXECUTION 1' r N O Confessed Judgment7371 cJ' .QC) vs. Max Stoner Plaintiff Q✓ Other File No. 14-3690 Amount Due $812,483.44 (plus post -judgment interest) Atty's Comm NIA Costs N/A Address: Garnishee: Laurel Office Associates do Max Stoner 5041 Woodbox Lane Mechanicsburg, Pennsylvania 17055 Defendant Interest TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) The interest of the Defendant in the Garnishee, in any assets of the Garnishee and in any income due from the Garnishee. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) The interest of the Defendant in the Garnishee, in any assets of the Garnishee and in any income due from the Garnishee. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). Date El (Indicate) Index this writ against the garnishee (s) as a lis d fendant(s) C6F ac). c r a9. ag 1-L 1co.So o t., O0._" ti escribed in the attached exhibit. 1� "' S2- .a6-pui a. Luk- Is�aa �3ga3 at9 Signature: Print Name: Address: Attorney for: Telephone: pendens against real ate,e€, the ....ca4 Eric S. Schuster 36 S. Charles St., 12th Floor Baltimore, Maryland 21201 Susquehanna Bank 410-659-4983 Supreme Court ID No: 85362 nk- - &(tf A THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net SUSQUEHANNA BANK Vs. MAX STONER WRIT OF EXECUTION (Pa R.C.P. 3252) NO 14-3690 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against MAX STONER, 5041 WOODBOX LANE, MECHANICSBURG, PA 17055 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of LAUREL OFFICE ASSOCIATES, C/O MAX STONER, 5041 WOODBOX LANE, MECHANICSBURG, PA 17055GARNISHEE(S), as garnishee, THE INTEREST OF THE DEFENDANT IN THE GARNISHEE, IN ANY ASSETS OF THE GARNISHEE AND IN ANY INCOME DUE FROM THE GARNISHEE. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other fmancial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $812,483.44 Plaintiff Paid Interest (PLUS POST -JUDGMENT INTEREST) Law Library Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $240.50 Other Costs Date: 11/25/14 (Sea REQUESTING PARTY: Name : ERIC S. SCHUSTER, ESQUIRE Address: FUNK & BOLTON 36 S. CHARLES ST., 12T11 FLOOR BALTIMORE, MD 21201 Attorney for: PLAINTIFF Telephone: 410-659-4983 Supreme Court ID No. 85362 /S/ /Gt G✓ ' ,e�L David D. Buell, Prothonotary By: i�YGiit�t /e: 4;?/ Deputy MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK CIVIL ACTION - LAW No.: 14-3690 Plaintiff, vs. ANSWERS TO IN I hRROGATORIES IN ATTACHMENT MAX STONER Defendant, and Filed on behalf of PNC Bank, National PNC BANK Garnishee Association Joel B. Gold, Esquire Sr. Counsel for PNC Bank, National Association Pa. I.D. #42090 PNC Bank, National Association Firm #862 One PNC Plaza, 20th Floor 249 Fifth Avenue Pittsburgh, Pennsylvania 15222-2707 (412) 762-2801/6763 (facsimile) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK Plaintiff, vs. MAX STONER Defendant, PNC BANK CIVIL ACTION - LAW No.: 14-3690 ANSWERS TO INTERROGATORIES IN ATTACHMENT and Filed on behalf of PNC Bank, National Association Garnishee ANSWERS TO INTERROGATORIES IN ATTACHMENT AND NOW, PNC Bank, N.A. the Garnishee ("Bank"), files this response stating as follows: 1. Unknown. The bank has one account in the name of the judgment defendant. The account, however, is carried on the records of the bank as an individual retirement account (IRA) and the bank is unable to admit or deny it as a debt owed for this attachment. The balance of the account, after allowance of the judgment defendant's $300.00 cash exemption and the Bank's $100.00 legal process services charge has a balance of $5,765.25. 2. No. 3. No. 4. No. 5. See no. 1. 6. No, see no. 1. 7. No. 8. No. WHEREFORE, PNC Bank, N.A. is not able to admit a debt due to the judgment defendant because on the bank's records the account is carried as an individual retirement account (TRA); and, PNC Bank, NA does not admit holding tangible personal property of the judgment defendant. Respectfully submitted, PNC BANK, NATIONAL ASSOCIATION Lit/garnishee answers/Stoner, Max 11072014 VERIFICATION The undersigned hereby verifies that I am an authorized representative of PNC Bank, N.A.; that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information and belief and that these statements are made subject to the penalties of 18Pa. C.S. s4904, relating to unsworn falsification to authorities. RE Susquehanna Bank vs Max Stoner DOCKET NO 14-3690 DATE: November 24, 2014 Lit -233946.1 Theresa A Dusch Team Lead, Garnishment Processing Position CERTIFICA'1E OF SERVICE PNC BANK, Garnishee, certifies that onlbe mIOCV 2 , 2014, a copy of the Answers to Interrogatories in Attachment was served via first-class U.S. mail to: the court where the Writ of Execution was filed; the plaintiff or counsel representing the plaintiff; and to the defendant(s). Date: N6V0tikNCY 25, 2014 Kristen Kinander, Paralegal PNC BANK, NATIONAL ASSOCIATION Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 26114 DEC 10 PM 3: ? L, CUMBERLAND COU'4< 's PENNSYLVANIA Susquehanna Bank vs. Max Stoner Case Number 2014-3690 SHERIFF'S RETURN OF SERVICE 12/10/2014 01:53 PM - Noah Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Laurel Office Associates c/o Max Stoner, 3075 Trindle Road, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Max Stoner, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to him. The writ of execution and notice to defendant was mailed on December 10, 2014 to Max Stoner at 5041 Woodbux Lane, Mechanicsburg, PA 17055. December 10, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. NOAH CLINE, DEPUTY SO ANSWERS, RONN Y R ANDERSON, SHERIFF SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee SUSQUEHANNA BANK vs. MAX STONER and : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND : NO. 14-3690 WELLS FARGO BANK N.A., GARNISHEE PRAECIPE TO THE PROTHONOTARY: Kindly enter a Rule upon Plaintiff to either seek judgment against Garnishee, Wells Fargo Bank, N.A., under Rule 3143(g) or to place the issue between Plaintiff and Garnishee upon the list for trial, or in the alternative, to suffer judgment of non pros against Plaintiff and in favor of Garnishee, Wells Fargo Bank, N.A. Date: ����� SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee SUSQUEHANNA BANK : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND vs. MAX STONER and : NO. 14-3690 WELLS FARGO BANK N.A., GARNISHEE RULE TO THE PROTHONOTARY: AND NOW, this Jay of , 2014, a Rule is hereby granted upon Plaintiff to seek judgment against Garnishee, Wells Fargo Bank, N.A., under Rule 3143(g) or to place the issue between Plaintiff, Defendant and Garnishee upon the list for trial within twenty (20) days after the service hereof or to suffer Judgment of Non Pros against Plaintiff. PROTHONOTARY SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee SUSQUEHANNA BANK : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND vs. MAX STONER and : NO. 14-3690 WELLS FARGO BANK N.A., GARNISHEE To: Eric S. Schuster, Esquire 36 South Charles Street Twelfth Floor Baltimore, Maryland 21201 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X PRAECIPE FOR RULE OF NON PROS JUDGMENT BY DEFAULT _ MONEY JUDGMENT _ JUDGMENT IN REPLEVIN _ JUDGMENT FOR POSSESSION _ JUDGMENT ON AWARD OF ARBITRATION _ JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee SUSQUEHANNA BANK vs. 2 Hf : COURT OF COMMON PLEAS • : COUNTY OF CUMBERLAND MAX STONER : NO. 14-3690 and WELLS FARGO BANK N.A., GARNISHEE : ATTORNEY ID# ?,-S 3 CoD, ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, Wells Fargo Bank, N.A., discontinued, upon payment of your costs only. ERIC S. SCHUSTER Attorney for Plaintiff a 64 ci,so444,_ 1 -fl) 2.4 ill sti