HomeMy WebLinkAbout14-4016 HAROLD F. RENSHAW, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
NO. >y - ilbl&
GLENWOOD, LLC,
DEFENDANT CONFESSION OF JUDGMENT
CONFESSION OF JUDGMENT
BY VIRTUE OF THE AUTHORITY CONFERRED BY THE NOTE DATED MAY 21,2009
A COPY OF WHICH IS ATTACHED TO THIS COMPLAINT I APPEAR FOR THE
DEFENDANT AND CONFESS JUDGMENT IN FAVOR OF THE PLAINTIFF AND
AGAINST THE DEFENDANT GLENWOOD, LLC FOR THE SUM OF THREE HUNDRED
SIXTY THREE THOUSAND NINE HUNDRED SEVENTY SIX AND 61/100
($363,976.61) DOLLARS AND COSTS OF SUIT PLUS $56.46 PER DIEM FROM
JULY 8,2014 UNTIL PAID IN FULL.
BY:
St en Howell. quire
owell Law irm
619 Bridge StreetZK
New Cumberland,PA 17070-OD
(717) 770-1277 Voice
(717) 770-1278 Fax -<> . CD =j
Attorney for Plaintiff �CD _Z- '
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DATE: July 7, 2014
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HAROLD F. RENSHAW, IN THE COURT OF COMMON PLEAS,
PLAINTIFF CUMBERLAND COUNTY,
PENNSYLVANIA �_
VS. `r �� C� CD
CJ 1
GLENWOOD, LLC, 7'C--)
DEFENDANT CONFESSION OF JUDGMENT D -_
NOTICE OF DEFENDANT'S RIGHTS
A judgment in the amount of THREE HUNDRED SIXTY THREE THOUSAND NINE
HUNDRED SEVENTY SIX AND 61/100 ($363,976.61) DOLLARS has been entered
against you and in favor of the PLAINTIFF without any prior notice of hearing based
on a confession of judgment contained in a written agreement or other paper
allegedly signed by you.The Sheriff may take your money or other property to pay
the judgment at any time after thirty(30) days after the date on which the notice is
served on you.
You may have legal rights to defeat the judgment or to prevent your money or
property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM
THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER
THE DATE ON WHICH THE NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR
RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER AND CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
PENNSYLVANIA LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Respectfully submitted,
BY:
St en Howell, Esq ' e
owell Law Firm
619 Bridge Street
New Cumberland,PA 17070
(717) 770-1277 Voice
(717) 770-1278 Fax
Attorney for Plaintiff
WHEREFORE,Plaintiff demands judgment against Defendant in the sum of
$363,976.61 together with interest of$56.46 per diem from July 8, 2014 and court
costs and fees recoverable under the parties'contract.
Respectfully submitted,
BY:
Stev owe , Esqu' e
ell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277 Voice
(717) 770-1278 Fax
Attorney for Plaintiff
Date: July 7, 2014
'VERIFICATION
I/we verify that the statements made in the foregoing document are true and
correct I/we understand that false statements herein are made subject to the
penalties of 18 Pa.C.S.A.Section 4904 relating to unsworn falsification to
authorities.
BY:
HAROLD F. RENSHAW
Date:
• c:\UVVJ\RL\rriV\JVCGrrJnir nutr J tlnr irVr� n�u
MORTGAGE NOTE-(BALLOON)
$368,000.00 MAY 12X , 2009
Date
FOR VALUE RECEIVED, the Undersigned, GLENWOOD, LLC, whose address is
5041A LANCASTER STREET, HARRISBURG, PA 17111 ("Borrower") , promises to pay to
HAROLD F. RENSHAW, ("Lender") , whose address is 211 Oberle Avenue, Baltimore,
MD 21221-4766 the principal sum of (US $) 368,000.00 together with interest
on the unpaid principal balance at the rate set forth below (the
"Obligation") .
To be repaid as follows:
This obligation shall be repayable in 59 consecutive equal monthly
installments of principal and interest and a final installment of all then
due principal, interest and fees thereon. The first scheduled monthly
payment shall be due :S-()412 'alk . 2009 , and continue to be due and
payable on the ST day of each month thereafter until MAY 2k ,2014 ,
(the "Maturity Date") at which time the final installment of all outstanding
principal and interest shall be due and payable.
The Applicable Rate of Interest is 6.00 % per annum.
My monthly payments will be in the amount of U.S.$ 2,206.35
Interest at the interest rate provided herein shall continue to accrue
and be paid and continue to be paid even after default, maturity, accelera-
tion, recovery of judgment, bankruptcy or insolvency proceedings of any kind
or the happening of any event or occurrence, similar or dissimilar.
All payments due under this Note shall be made at a.kkybeA2 Au<
('-%,6 21 22 l -L(lU
This Note may be prepaid at any time in whole or in part, without
penalty, but all prepayments shall be applied to any installments of
principal then outstanding in the inverse order of their maturity.
If at any time the Borrower shall fail to pay any installment of
principal or interest in full hereunder for a period of 10 days after such
payment shall be due, the Borrower promises to pay, to the extent permitted
by law, a delinquency charge of 5% to each such installment or part thereof.
The term "Collateral" means the following property in which a security
interest is hereby granted to Lender: A valid first mortgage lien on real
estate and improvements located in 3803 GLENWOOD AVENUE, CAMP HILL, PA 17011
described in more detail in the mortgage of this same date.
The occurrence of any of the following shall be a default hereunder: (a)
the nonpayment 10 days after the date due of any amount(s) payable on any of
the Liabilities; (b) failure of the Borrower to perform any agreement
hereunder; (c) the filing of any petition under any bankruptcy or insolvency
laws, state or federal, by or against any Borrower; (d) an application for
the appointment of a custodian, receiver, trustee, sequestrator, liquidator,
conservator, or other judicial officer similar or dissimilar, or the
insolvency or the making of any assignment for the benefit of creditors by
any Borrower; (e) the entry of any judgment against any Borrower; (f) the
issuance of any attachment or garnishment or the attaching of any lien
against any property of any Borrower; (g) the seizure, condemnation or
EXHIBIT
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forfeiture of a substantial part of any Borrower's property at the instance
of any government or governmental agency or instrumentality, local, state or
federal; (h) the dissolution, merger, consolidation, reorganization or sale
of substantially all of the assets of any Borrower; (i) the commencement of
proceedings for the dissolution, merger, consolidation, reorganization, or
sale of substantially all of the assets of any Borrower; (j) the assignment
by the Borrower of any interest in any, or the existence of any lien or
security interest of the Collateral, other than Lender's.
Upon the occurrence of a default and after 30 days notice to Borrower of
the default and Borrower's failure to cure the default within the said 30 day
period: (i) all Liabilities shall, at the option of the holder of this Note,
be immediately due and payable without notice or demand on any Borrower and
without requiring any recourse against any person or property liable for or
securing any of the Liabilities; (ii) Lender shall have the immediate right
of setoff against the Liabilities of any indebtedness owed by Lender to each
Borrower, whether or not due, and Lender shall be deemed to have exercised
such right and charged each Borrower's indebtedness immediately upon the
occurrence of such default even if Lender does not enter such charge on its
books immediately; (iii) all of Lender's rights and remedies hereunder, under
any other documents now or hereafter executed, or under any laws shall be
cumulative and may deem appropriate.
Time is of the essence.
The Borrower waives presentment, demand, notice of dishonor, protest and
notice of protest. The liability of the Borrower shall be unconditional and
absolute without regard to the liability of any other party, and shall not be
affected by additions to, exchanges of or substitutions for the Collateral
nor any indulgence granted or consented to by Lender, including, without
limitation, and release of any party or release of any Collateral, extension
of time, renewal, waiver or other modification. Any failure of Lender to
exercise the same right at any time and from time to time thereafter.
The Borrower waives and releases their rights under any and all
appraisement, stay or exemption laws, existing now or hereafter and agree
that Pennsylvania law shall govern any issue arising hereunder. The
Undersigned intend this to be a sealed instrument and to be legally bound
hereby.
The Borrowers each irrevocably consent to the exclusive jurisdiction of
the Courts of Common Pleas in the Commonwealth of Pennsylvania or a United
States District Court in Pennsylvania in any and all actions and proceedings,
whether arising hereunder or under any other agreement or undertaking and
irrecoverably agree to Service of Process by certified mail, return receipt
requested, within or without the Commonwealth of Pennsylvania, and that such
service upon any of the Borrowers shall constitute service upon all of them,
each, hereby appointing the other(s) their attorney-in-fact for the purpose
of service. The Borrowers further agree not to make any objection in any
such action(s) or proceedings that the venue is improper or the forum is
inconvenient.
THE BORROWERS, AS AN INDEPENDENT COVENANT IRREVOCABLY, WAIVE JURY TRIAL
AND THE RIGHT HERETO IN ANY AND ALL DISPUTES BETWEEN ANY BORROWER AND LENDER,
WHETHER HEREUNDER OR UNDER ANY OTHER AGREEMENTS, INSTRUMENTS, OR DOCUMENTS
HERETOFORE OR HEREAFTER EXECUTED, WHETHER SIMILAR OR DISSIMILAR.
Borrowers each hereby agree to pay all costs of collection incurred by
Lender, including without limitation, attorney's fees.
THE BORROWER DOES HEREBY IRREVOCABLY AUTHORIZE AND EMPOWER THE
PROTHONOTARY OR CLERK OR ANY ATTORNEY OF ANY COURT OF RECORD OF PENNSYLVANIA
-2-
OR ELSEWHERE, TO IMMEDIATELY OR HEREAFTER APPEAR FOR THEM OR ANY OF THEM WITH
OR WITHOUT DEFAULT AND WITH OR WITHOUT DEMAND HEREUNDER, AND CONFESS
JUDGMENTS AGAINST ONE, ANY AND ALL OF THE BORROWER, FOR THE UNPAID BALANCE OF
PRINCIPAL HEREOF AND ANY OTHER SUMS DUE HEREUNDER PLUS INTEREST AND COST,
WITH OR WITHOUT DECLARATION FILED, AND WITH RELEASE OF ERRORS, WITHOUT STAY
OF EXECUTION AND WITH FIVE (50) PERCENT ADDED FOR COLLECTION FEES. THE
BORROWER ALSO AGREES TO CONDEMNATION OF ANY PROPERTY LEVIED UPON BY VIRTUE OF
ANY EXECUTION ISSUED UNDER ANY SUCH CONFESSED JUDGMENT AND WAIVES ALL
EXEMPTIONS FOR LEVY AND SALE OF ANY PROPERTY THAT NOW IS OR HEREAFTER MAY BE
EXERCISED AS OFTEN AS LENDER REQUIRES AND SHALL NOT BE EXHAUSTED BY ONE OR
MORE OR BY ANY IMPERFECT EXERCISE THEREOF AND SHALL BE REPEATEDLY AVAILABLE
UNTIL LENDER HAS RECEIVED FULL PAYMENT OF THE PRINCIPAL AMOUNT HEREOF AND ALL
OTHER SUMS DUE LENDER. NO SINGLE EXERCISE OF THE FOREGOING POWER TO CONFESS
A JUDGMENT, OR A SERIES OF JUDGMENTS SHALL BE DEEMED TO EXHAUST THE POWER,
WHETHER OR NOT SUCH EXERCISE SHALL BE HELD BY ANY COURT TO BE VALID,
AVOIDABLE, OR VOID, BUT THE POWER SHALL CONTINUE UNDIMINISHED AND IT MAY BE
EXERCISED FROM TIME TO TIME AS OFTEN AS A HOLDER HEREOF SHALL ELECT UNTIL
SUCH TIME AS THE HOLDER SHALL HAVE RECEIVED PAYMENT IN FULL OF THE DEBT, SUMS
PAID, BE INVALID OR UNENFORCEABLE THE VALIDITY OR ENFORCEABILITY OF ANY OTHER
PROVISION OF THIS NOTE SHALL NOT BE AFFECTED THEREBY.
Witness/Attest Borrower:
,GLV:0OD, LLCby (SEAL)
P. Jo n Sopen k , sole member
-3-
HOWELL LAW FIRM
619 Bridge Street,New Cumberland, Pennsylvania 17070
Telephone 717-770-1277
Fax 717-770-1278
****VIA HAND DELIVERY BY PA CONSTABLE****
June 4, 2014
P.John Sopenski P.John Sopenski
Agent for Glenwood LLC Agent for Glenwood LLC
1300 Market Street 3801 Glenwood Avenue
Lemoyne,PA 17043 Camp Hill,PA 17011
RE: Mortgage Payoff for 3803 Glenwood Avenue, Camp Hill, PA 17011
Dear Mr.Sopenski:
I am the attorney for Harold F.Renshaw. As a follow up to my letter of May 19th,you
have failed to pay the balloon payment to Mr.Renshaw due May 21, 2014. Under the terms
of the Mortgage Note (Balloon) dated May 21,2009,Glenwood LLC borrowed$368,000.00
at 6.00% per annum with monthly payments of principal and interest of$2,206.35. The
"maturity date"for the Mortgage Note is May 21, 2014 and the payoff was Three Hundred
Forty Four Thousand One Hundred Seventeen and 14/100 ($344,117.14) Dollars.
This payoff is based upon the amortization chart of$342,931.48 plus interest of$1,185.6,6
calculated for 21 days in May at$56.46 per diem.
Because you failed to pay the balloon payment on May 21, 2014,you have incurred a
5% delinquency charge which states: "If at any time the Borrower should fail to pay any
installment of principal or interest in full hereunder for a period of 10 days after such
payment shall be due,the Borrower promises to pay,to the extent permitted bylaw,a
delinquency charge of 5%to each such installment or part thereof." Therefore,as of Juge 4,
2014 you owe the following sums:
Balloon Payment $ 344,117.14 (as of 5/21/14)
Per Diem $ 790.44 ($56.46 for 5/22/14-6/4/14)
5% Delinquency $ 17.205.85
$362,113.43 plus$56.46 per diem from 6/5/14
PLEASE CONSIDER THIS LETTER YOUR WRITTEN NOTICE TO CURE THE
DEFAULT WITHIN THIRTY(30) DAYS. IF YOU FAIL TO CURE THE DEFAULT BY
PAYING $362,113.43 PLUS$56.46 PER DIEM FROM 6/5/14 UNTIL THE DATE OF YOUR
PAYMENT,THE ENCLOSED COMPLAINT TO OBTAIN A CONFESSION OF JUDGMENT
SHALL BE FILED AT THE EXPIRATION OF THE THIRTY DAYS.,
Very truly yours,
XSven How 1, Esquire '
SH/bth
cc: Harold F. Renshaw
EXHIBIT
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m
HAROLD F. RENSHAW, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
NO.
GLENWOOD, LLC,
DEFENDANT CONFESSION OF JUDGMENT
CONFESSION OF JUDGMENT
BY VIRTUE OF THE AUTHORITY CONFERRED BY THE NOTE DATED MAY 21,2009
A COPY OF WHICH IS ATTACHED TO THIS COMPLAINT I APPEAR FOR THE
DEFENDANT AND CONFESS JUDGMENT IN FAVOR OF THE PLAINTIFF AND
AGAINST THE DEFENDANT GLENWOOD, LLC FOR THE SUM OF THREE HUNDRED
SIXTY TWO THOUSAND ONE HUNDRED THIRTEEN AND 43/100 ($362,113.43)
DOLLARS AND COSTS OF SUIT.
BY:
Steven Howell, Esquire
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277 Voice
(717) 770-1278 Fax
Attorney for Plaintiff
DATE: July 2014
r
rt
HAROLD F. RENSHAW, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
NO.
GLENWOOD, LLC,
DEFENDANT CONFESSION OF JUDGMENT
NOTICE OF DEFENDANT'S RIGHTS
A judgment in the amount of THREE HUNDRED SIXTY TWO THOUSAND ONE
HUNDRED THIRTEEN AND 43/100 ($362,113.43) DOLLARS has been entered
against you and in favor of the PLAINTIFF without any prior notice of hearing based
on a confession of judgment contained in a written agreement or other paper
allegedly signed by you.The Sheriff may take your money or other property to pay
the judgment at any time after thirty(30) days after.the date on which the notice is
served on you.
You may have legal rights to defeat the judgment or to prevent your money or
property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM
THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER
THE DATE ON WHICH THE NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR
RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER AND CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
PENNSYLVANIA LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Respectfully submitted,
BY:
Steven Howell, Esquire
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277 Voice
(717) 770-1278 Fax
Attorney for Plaintiff
7. The obligations of Defendant are in default,among other things,by
reason of its failure to make the required balloon payment due under the
Note on or before May 21, 2014. The ten day grace period expired on
June 1, 2014.
8. The.principal amount due on the Note as,of May 2l; 2014.is$344,117.14;
plus a per diem rate of$56.46 since that time or$790.44 for the period
May 21, 2014 to June 4,2014; plus 5% delinquency charge of$17,205.85
and attorneys fees and court costs.
9. Plaintiff has been advised and,therefore,avers that the Defendant
executed the Note attached as Exhibit"A" for business purposes.
10. The confession of judgment is not being filed against a natural person(s)
in regards-to consumer credit transaction.
WHEREFORE,Plaintiff demands judgment against Defendant in the sum of
$362,113.43 together with interest of$56.46'per diem from June 5, 2014 and
attorneys' fees and court costs.
Respectfully submitted,
BY: ;
Steven Howell, Esquire
Howell Law Firm
619 Bridge Street
New Cumberland; PA 17070
(717) 770-1277 Voice
(717) 770-1278 Fax
Attorney for Plaintiff
Date: June 4, 2013
forfeiture of a substantial part of any Borrower's property at the instance
of any government or governmental agency or instrumentality, local, state or
federal; (h) the dissolution, merger, consolidation, reorganization or sale
of substantially all of the assets of any Borrower; (i) the commencement of
proceedings for the dissolution, merger, consolidation, reorganization, or
sale of substantially all of the assets of any Borrower; (j) the assignment
by the Borrower of any interest in any, or the existence of any lien or
security interest of the Collateral, other than Lender's.
Upon the occurrence of a default and after 30 days notice to Borrower of
the default and Borrower' s failure to cure the default within the said 30 day
period: (i) all Liabilities shall, at the option of the holder of this Note,
be immediately due and payable without notice or demand on any Borrower and
without requiring any recourse against any person or property liable for or
securing any of the Liabilities; (ii) Lender shall have the immediate right
of setoff against the Liabilities of any indebtedness owed by Lender to each
Borrower, whether or not due, and Lender shall be deemed to have exercised
such right and charged each Borrower's indebtedness immediately upon the
occurrence of such default even if Lender does not enter such charge on its
books immediately; (iii) all of Lender's rights and remedies hereunder, under
any other documents now or hereafter executed, or under any laws shall be
cumulative and may deem appropriate.
Time is of the essence.
The Borrower waives presentment, demand, notice of dishonor, protest and
notice of protest. The liability of the Borrower shall be unconditional and
absolute without regard to the liability of any other party, and shall not be
affected by additions to, exchanges of or substitutions for the Collateral
nor any indulgence granted or consented to by Lender, including, without
limitation, and release of any party or release of any Collateral, extension
of time, renewal, waiver or other modification. Any failure of Lender to
exercise the same right at any time and from time to time thereafter.
The Borrower waives and releases their rights under any and all
appraisement, stay or exemption laws, existing now or hereafter and agree
that Pennsylvania law shall govern any issue arising hereunder. The
Undersigned intend this to be a sealed instrument and to be legally bound
'hereby.
The Borrowers each irrevocably consent to the exclusive jurisdiction of
the Courts of Common Pleas in the Commonwealth of Pennsylvania or a United
States District Court in Pennsylvania in any and all actions and proceedings,
whether arising hereunder or under any other agreement or undertaking and
irrecoverably agree to Service of Process by certified mail, return receipt
requested, within or without the Commonwealth of Pennsylvania, and that such
service upon any of the Borrowers shall constitute service upon all of them,
each, hereby appointing the other(s) their attorney-in-fact for the purpose
of service. The Borrowers further agree not to make any objection in any
such action(s) or proceedings that the venue is improper or the forum is
inconvenient.
THE BORROWERS, AS AN INDEPENDENT COVENANT IRREVOCABLY, WAIVE JURY TRIAL
AND THE RIGHT HERETO IN ANY AND ALL DISPUTES BETWEEN ANY BORROWER AND LENDER,
WHETHER HEREUNDER OR UNDER ANY OTHER AGREEMENTS, INSTRUMENTS, OR DOCUMENTS
HERETOFORE OR HEREAFTER EXECUTED, WHETHER SIMILAR OR DISSIMILAR.
Borrowers each hereby agree to pay all costs of collection incurred by
Lender, including without limitation, attorney's fees.
THE BORROWER DOES HEREBY IRREVOCABLY AUTHORIZE AND EMPOWER THE
PROTHONOTARY OR CLERK OR ANY ATTORNEY OF ANY COURT OF RECORD OF PENNSYLVANIA
-2-
OR ELSEWHERE, TO IMMEDIATELY OR HEREAFTER APPEAR FOR THEM OR ANY OF THEM WITH
OR WITHOUT DEFAULT AND WITH OR WITHOUT DEMAND HEREUNDER, AND CONFESS
JUDGMENTS AGAINST ONE, ANY AND ALL OF THE BORROWER, FOR THE UNPAID BALANCE OF
PRINCIPAL HEREOF AND ANY OTHER SUMS DUE HEREUNDER PLUS INTEREST AND COST,
WITH OR WITHOUT DECLARATION FILED, AND WITH RELEASE OF ERRORS, WITHOUT STAY
OF EXECUTION AND WITH FIVE (5%) PERCENT ADDED FOR COLLECTION FEES. THE
BORROWER ALSO AGREES TO CONDEMNATION OF ANY PROPERTY LEVIED UPON BY VIRTUE OF
ANY EXECUTION ISSUED UNDER ANY SUCH CONFESSED JUDGMENT AND WAIVES ALL .
EXEMPTIONS FOR LEVY AND SALE OF ANY PROPERTY THAT NOW IS OR HEREAFTER MF,Y BE
EXERCISED AS OFTEN AS LENDER REQUIRES AND SHALL NOT BE EXHAUSTED BY ONE OR
MORE OR BY ANY IMPERFECT EXERCISE THEREOF AND SHALL BE REPEATEDLY AVAILABLE
UNTIL LENDER HAS RECEIVED FULL PAYMENT OF THE PRINCIPAL AMOUNT HEREOF AND ALL
OTHER SUMS DUE LENDER. NO SINGLE EXERCISE OF THE FOREGOING POWER TO CONFESS
A JUDGMENT, OR A SERIES OF JUDGMENTS SHALL BE DEEMED TO EXHAUST THE POWER;
WHETHER OR NOT SUCH EXERCISE SHALL BE HELD BY ANY COURT TO BE VALID,
AVOIDABLE, OR VOID, BUT THE POWER SHALL CONTINUE UNDIMINISHED AND IT MAY BE
EXERCISED FROM TIME TO TIME AS OFTEN AS A HOLDER HEREOF SHALL ELECT UNTIL
SUCH TIME AS THE HOLDER SHALL HAVE RECEIVED PAYMENT IN FULL OF THE DEBT, SUMS
PAID, BE INVALID OR UNENFORCEABLE THE VALIDITY OR ENFORCEABILITY OF ANY OTHER
PROVISION OF THIS NOTE SHALL NOT BE AFFECTED THEREBY.
Witness/Attest Borrower:
,,GL �NOOD, LLC, by
(SEAL)
P. Jo n Sopen k , sole member
-3-
HAROLD F. RENSHAW, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
N0,
GLENWOOD, LLC,
DEFENDANT CONFESSION OF JUDGMENT
NOTICE
TO: GLENWOOD, LLC.
c/o P.John Sopenski
1300 Market Street
Lemoyne,PA 17043
YOU ARE HEREBY NOTIFIED THAT ON JUNE� 2014 JUDGMENT BY CONFESSION WAS
ENTERED AGAINST YOU IN THE SUM OF THREE HUNDRED SIXTY TWO THOUSAND ONE
HUNDRED THIRTEEN AND 43/100 ($362,113.43) DOLLARS IN THE ABOVE CAPTIONED
CASE.
BY:
Prothonotary
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER AND CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
PENNSYLVANIA LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 South Bedford Street
Carlisle,PA 17013
(717) 249-3166
I HEREBY CERTIFY THAT THE FOLLOWING IS THE ADDRESS OF THE DEFENDANT STATED
IN THE COMPLAINT:
GLENWOOD,LLC.
c/o P.John Sopenski
1300 Market Street
Lemoyne, PA 17043
BY:
Steven Howell, Esquire
Howell Law Firm
619 Bridge Street
New Cumberland,PA 17070
(717) 770-1277 Voice
(717) 770-1278 Fax
Attorney for Plaintiff
DATE:July_,2014
Defendant Plaintiff Person Served
Name: �(� ��� So Q 9A 6 i Name: _ /4J`'D�/� -; }�eN� Name:
Address: Y6D I rg,):C�wood Address: Address: 1366 MAkI[A 6
x m;,e, A/a,9L
City: ry)j2 ,1 I City: City:
State: Zip: State: Zip: State: Zip: 17,6
DESCRIPTION BELOW
❑ CIVIL ACTION ❑ SUBPOENA ❑ DIVORCE ('OTHER - EXP.BELOW
DOCKET # 4- DATE: `/�l c f DAY: TIME: T d
TITLE of PERSON SERVED
comments I remarks
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I verify that the statements in the "Return of.Service" are true and correct. I understand that false statements herein are made
subject to the penalties of 18Pa. C.S.A. 4904 relating to unsworn falsification to authorities.
A tQmq 1 Judge Expenses Pa.State Constable
Name: P-1 Cost: IS-,, Name:Ak&J4j twtk, J 717 512-8925
Address: &vq , Ju (%)A ,c if Lr Mileage:
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HAROLD F.RENSHAW, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
NO. 1y -- j161&
GLENWOOD, LLC,
DEFENDANT CONFESSION OF JUDGMENT
NOTICE
TO: GLENWOOD,LLC.
c/o P.John Sopenski
1300 Market Street
Lemoyne,PA 17043
YOU ARE HEREBY NOTIFIED THAT ON JULY 2014 JUDGMENT BY CONFESSION
WAS ENTERED AGAINST YOU IN THE SUM OF THREE HURQREDALXTY, E
THOUSAND NINE HUNDRED SEVENTY SIX AND 61/100 63,97 1) LARS I
THE ABOVE CAPTIONED CASE.
BY:
OF
lr-PT90116notary
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER AND CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
PENNSYLVANIA LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 South Bedford Street
Carlisle;PA 17013
(717) 249-3166
I HEREBY CERTIFY THAT THE FOLLOWING IS THE ADDRESS OF THE DEFENDANT STATED
IN THE COMPLAINT:
GLENWOOD,LLC.
c/o P.John Sopenski
1300 Market Street
Lemoyne,PA 17043
BY:
Steekovkh, squire
well Law Firm
619 Bridge Street
New Cumberland,PA 17070
(717) 770-1277 Voice
(717) 770-1278 Fax
Attorney for Plaintiff
DATE:July 7,2014
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff t;E_.ED"OF F IC,X
cp',0,r o1 EaoRtiewOF THE PROTHONOTARY
PtKi 2014 JUL 3 P AM 10: 38
OFFICE OFTHE £KERIFF CUMBERLAND COUNTY
PENNSYLVANIA
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Harold F Renshaw
vs. Case Number
Glenwood, LLC 2014-4016
SHERIFF'S RETURN OF SERVICE
07/10/2014 12:50 PM - Deputy Tim Black, being duly sworn according to law, served the requested Complaint in
Confession of Judgment by handing a true copy to a person representing themselves to be John
Sopenski, who accepted as "Adult Person in Charge" for Glenwood, LLC at 1300 Market Street, Lemoyne
Borough, Lemoyne, PA 17043.
SHERIFF COST: $46.08 SO ANSWERS,
July 14, 2014
(c) CountySuite Sheriff, Teleosofi, Inc.
RONNY R ANDERSON, SHERIFF
HAROLD F. RENSHAW
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
V. CIVIL ACTION — LAW
GLENWOOD, LLC.
DEFENDANT NO. 14-4016
PRAECIPE TO SATISFY JUDGMENT c->
-.,Q 3
.
TO THE PROTHONOTARY:
Please issue a praecipe that the Defendant Glenwood, LLC. has settled and paid in agile --ca
Judgment by Confession issued July 8, 2014.
Respectfully submitted,
By:
Mo
4,>
Date: July 30, 2014
n Howell .%'squire
owell Law Firm
619 Bridge Street
New Cumberland, PA 17070
Supreme Court ID 62063