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Home My WebLink About14-5059 HARTMAN SH URR } '� } r'tr Attorneys for Plaintiff Dominic A. DeCecco, Esquire Attorney I.D. #79479 1100 Berkshire Blvd., Suite 301 P.O. Box 5828 Wyomissing, PA 19610 (610) 779-0772 WOORI AMERICA BANK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW VS. SUN Y1 CHON, Defendant NO. JH PRAECIPE TO TRANSFER AND ENTER EXEMPLIFIED JUDGMENT To: Prothonotary of Cumberland County Please transfer and enter the attached Exemplified Judgment in favor of Plaintiff, Woori America Bank, and against the Defendant, Sun Yi Chon, in the amount of $1,015,150.84, together with interest from April 24, 2013 forward at the default interest rate of 16% per annum ($372.56 per diem), late charges, attorneys' fees, and collection costs. HART HURR By: bbT61'n A. DeCecc'oftsquire 1100 Berkshire Blvd., Suite 301 P.O. Box 5828 Wyomissing, PA 19610 (610) 779-0772 Attorneys for Plaintiff Supporting Documentation: Certified Docket Entries/Exemplified Judgment 633.sq)d 0 C Q ,,c/q7d 2 ?(b sql IIJOAC 171a('�eol t � 31n Ebe (Court of Common VCeao of Maupbin QCouutp, Vennopfbania Woori America Bank VS. No. 2013 -CV- 03903 -NT Sun Yi Chon CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that judgment was entered in favor of Plaintiff, Woori America Bank and against Defendant, Sun Yi Chon on May 3, 2013 in said case in the amount of $1,015,150.84 In Teotimoup Wbereof, I have hereunto set my hand and affixed the se o the Court, on Friday, August 22, 2014. Prothono By: Deputy Bate: 8/22/2014 Dauphin County User: JMAURER Time: 11:17 AM Complete Case History Page 1 of 3 Case: 2013 -CV- 03903 -NT Wood America Bankvs.Sun Yi Chon Filed: 5/3/2013 Subtype: Notes Physical File: Y Appealed: N Comment: Status History Pending 5/3/2013 Pending / Judgment 5/3/2013 Judge History Date Judge Reason for Removal 5/3/2013 No Judge, Current Payments Receipt Date Type Amount Hartman Shurr 294906 5/3/2013 Civil Filing 51.75 295623 5/17/2013 Civil Filing 37.75 322450 8/22/2014 Miscellaneous 26.25 Exemplified Record 26.25 Total 115.75 Miscellaneous Receipts Receipt Date 322450 8/22/2014 Exemplified Record 26.25 Sum: 26.25 Plaintiff Name: Wood America Bank SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys DeCecco, Dominic A (Primary attorney) Send Notices Defendant Name: Chon, Sun Yi SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys DeCecco, Dominic A (Primary attorney) Send Notices Register of Actions 5/3/2013 New Civil Case Filed This Date. No Judge, Date: 8/22f2014 Dauphin County User: JMAURER Time: 11:17 AM Complete Case History Page 2 of 3 Case: 2013 -CV- 03903 -NT Wood America Bankvs.Sun Yi Chon Register of Actions 5/3/2013 Plaintiff: Woori America Bank Attorney of No Judge, Record: Dominic A DeCecco Filing: Complaint with Confession of No Judge, Judgment Paid by: Hartman Shurr Receipt number: 0294906 Dated: 5/3/2013 Amount: $51.75 (Check) For: Chon, Sun Yi (defendant) Defendant: Chon, Sun Yi Attorney of No Judge, Record: Dominic A DeCecco On Complaint filed Judgment in No Judge, favor of Plaintiff and against Defendant in the sum of One Million Fifteen Thousand One Hundred Fifty and 84/100 Dollars ($1,015,150.84) by virtue of authority contained in the Warrant of Attorney filed dated 5/8/06 payable installments with interest, costs, etc. - -- for colt'n. Inquisition and Exemption Waived. Entered At 2:36 p.m. Stephen E. Farina, Prothonotary Copies of all documents mailed. 5/17/2013 Filing: Writ of Execution Paid by: No Judge, Hartman Shurr Receipt number: 0295623 Dated: 5/17/2013 Amount: $37.75 (Check) For: Woori America Bank (plaintiff) Writ of Execution No Judge, Garnishee - Sheriff - Dauphin County Amount Due $1,015,150.84 + costs. See Praecipe, filed. 6/3/2013 Proof of Service of notice(s) of sheriffs No Judge, sale of real property, filed. 6/6/2013 Proof of Service - returned mail, filed. No Judge, 6/25/2013 Proof of Service of notice(s) of sale, filed. No Judge, Amended affidavit pursuant to rule 3129. 1, No Judge, filed. 7/8/2013 Proof of Service - Returned Mail of the No Judge, Notice of Sheriffs Sale of Real Property, filed. 9/9/2013 Motion to Continue Sheriffs Sale of No Judge, Defendant's Real Property, filed. Certificate of Service of the Plaintiffs No Judge, Motion to Continue Sheriffs Sale of Real Property, filed. Certification of Addresses, filed. No Judge, 9/10/2013 Motion to Continue Sheriffs Sale Clark, Lawrence F. Jr. APPROVED BY ORDER OF COURT. See COMPLETE ORDER filed. Copies dist by Crt Admin on 9/11/13. Date: 1 8/22/2014 Dauphin County User: JMAURER Time: 11:17 AM Complete Case History Page 3 of 3 Case: 2013 -CV- 03903 -NT Wood America Bankvs.Sun Yi Chon Register of Actions 5/8/2014 Second amended affidavit pursuant to rule No Judge, 3129.1, filed. Proof of Service of notice of sheriffs sale, No Judge, filed. 6/4/2014 Plaintiffs emergency motion (uncontested) No Judge, to continue sheriffs sale of defendant's real property, filed. Motion to Continue Sheriffs Sale Coates, Bernard L Jr APPROVED BY ORDER OF COURT. See COMPLETE ORDER filed. Copies dist by Crt Admin on 6/5/14. 8/22/2014 Miscellaneous Payment: Exemplified No Judge, Record Paid by: Hartman Shurr Receipt number: 0322450 Dated: 8/22/2014 Amount: $26.25 (Check) Judgment Order date In Favor Of Disposition Judgment 05/03/2013 Plaintiff 05/03/2013 Open Judgment Comment: 1015150.84 Plaintiff: Wood America Bank Defendant: Chon, Sun Yi Judgment Order date In Favor Of Disposition Judgment 05/17/2013 Plaintiff 05/17/2013 Open Writ of Execution Comment: 1015150.84 Plaintiff: Wood America Bank Defendant: Chon, Sun Yi AUG 22 2014 I hereby certify that the foregoi g i a true and co c cof y t)pqt on i s filed. Prothonotary CaP.1L OF ALL. MOD WOORI AMERICA BANK, IN THE COURT OF COMMON PLEAS OF Plaintiff DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION — LAW VS. i CONFESSION OF JUDGMENT SUN YI CHON, Defendant NO. t l.Y J ��✓ I RULE 236 NOTICE To: Sun Yi Chon 227 Ewe Road j Mechanicsburg, PA 17055 MAY 0 3 2013 You are hereby notified that on , 2013, the foll i Judgment has been entered against you in the above - captioned case. Date: t 013 Prothonotary of Dauphin County I hereby certify that the name and address of the proper person(s) to receive this notice is: Sun Yi Chon o 227 Ewe Road - Mechanicsburg, PA 17055 HARTM SHURR i w 01 By: nic A. DeCecco, squire Attorneys for Plaintiff A , Defendido/a Defendidos /as MAY Por este medio se le esta notificando que el de 2 del el/la siguiente ❑ Orden ❑ Decreto ❑ Fallo ha sido anotado en contra suya en el caso cionado en el epigrafe. MAY FECHA: Prothonotario Certifico que is siguiente direction es la del defendido /a sigun indicada en el. r certificado de residencia: �11U 2 Abogado del Demandante € C�f VtE1� k j J I HARTMAN SHURR Attorneys for Plaintiff Dominic A. DeCecco, Esquire Attomey I.D. #79479 1100 Berkshire Blvd., Suite 301 P. O. Box 5828 Wyomissing, PA 19610 610 -779 -0772 WOORI AMERICA BANK, IN THE COURT OF COMMON PLEAS OF Plaintiff DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION — LAW VS . . CONFESSION OF JUDGMENT SUN YI CHON, Defendant NO. NOTICE UNDER 42 Pa.C.S. §2737.1 ism INSTRUCTIONS REGARDING THE PROCEDURE - TO FOLLOW TO STRIKE THE JUDGMENT To: Sun Yi Chon . c.a 227 Ewe Road ON Mechanicsburg, PA 17055 Pursuant to 42 Pa.C.S.A. Section 2737.1, the following instructions regarding the procedure to follow to strike the judgment in this matter are hereby provided: 1. The procedure to follow to strike a judgment by confession is set forth in Pa.R.C.P. 2959, which provides as follows: (a) (1) Relief from a judgment by confession shall be sought by petition. Except as provided in subparagraph (2), all grounds for relief whether to strike off the judgment or to open it must be asserted in a single petition. The petition may be filed in the county in which the judgment was originally entered, in any county to which the judgment has been transferred or in any other county in which the sheriff has received a writ of execution directed to the sheriff to enforce the judgment. (2) The ground that the waiver of the due process of rights of notice and hearing was not voluntary, intelligent any knowing shall be raised only (i) in support of a further request for a stay of execution where the court has not stayed execution despite the timely filing of a petition for relief from the judgment and the presentation of prima facie evidence of a defense; and (ii) as provided by Rule 2958.3 or Rule 2973.3. (3) If written notice is served upon the petitioner pursuant to Rule 2956.1(c)(2) or Rule 2973.1(c), the petition shall be filed within thirty (30) days after such service. Unless the defendant can demonstrate that there were compelling reasons for the delay, a petition not timely filed shall be denied. (b) If the petition states prima facie grounds for relief, the court shall issue a rule to show cause and may grant a stay of proceedings. After being served with a copy of the petition the plaintiff shall file an answer on or before the return day of the rule. The return day of the rule shall be fixed by the court by local rule or special order. (c) A party waives all defenses and objections which are not included in the petition or answer. (d) The petition and the rule to show cause and the answer shall be served as provided in Rule 440. (e) The court shall dispose of the rule on petition and answer and on any testimony, depositions, admissions and other evidence. The court for cause shown may stay proceedings on the petition insofar as it seeks to open the judgment pending disposition of the application to strike off the judgment. If evidence is produced which in a jury trial would require the issues to be submitted to the jury the court shall open the judgment. (f) The lien of the judgment or of any levy or attachment shall be preserved while the proceedings to strike off or open the judgment are pending. 2. Under 42 Pa.C.S.A. Section 2737.1, you are entitled to costs and reasonable attorney fees as determined by the court if you are incorrectly identified and had judgment entered against you. HARTM SHURR By: - ` inic A. DeCe , Esquire 1100 Berkshire Blvd., Suite 301 P.O. Box 5828 Wyomissing, PA 19610 (610) 779 -0772 Attorneys for Plaintiff HARTMAN SHURR Attorneys for Plaintiff Dominic A. DeCecco, Esquire Attorney I.D. #79479 1100 Berkshire Blvd., Suite 301 P. O. Box 5828 Wyomissing, PA 19610 610 -779 -0772 -' WOORI AMERICA BANK, IN THE COURT OF COMMON PLEAS OF Plaintiff DAUPHIN COUNTY, PENNSYLVANIA_, CIVIL ACTION - LAW VS. CONFESSION OF JUDGMENT SUN YI CAON, �0 Defendant NO. CONFESSION OF JUDGMENT 1 appear for the Defendant, Sun Yi Chon, by the authority contained in the Promissory Note executed by the Defendant in favor of the Plaintiff, a true and correct copy of which is attached as an Exhibit to the Complaint filed in this action, and confess judgment in favor of the Plaintiff and against the Defendant, Sun Yi Chon, as follows: Outstanding Principal Balance $ 838,258.28 Accrued Interest at the default interest rate of 16% per annum ($372.56 per diem) as of 4/24/13 $ 79,905.96 Late Charges as of 4/24/13 $ 4,700.16 Attorneys' Commission (10 %) $ 92,286.44 Total Amount Due as of 4/24/13 $1.015,150.84 Under the terms of the Note, the Plaintiff is also entitled to reimbursement for all late charges, attorneys' fees, and other costs of collection. WHEREFORE, the Plaintiff demands judgment against the Defendant, Sun Yi Chon, in the total amount of $1,015,150.84, together with interest from April 24, 2013 forward at the default interest rate of 16% per annum ($372.56 per diem), late charges, attorneys' fees, and collection costs. HARTMA SHURR B G "inic A. DeCe ;Esquire Attorneys for Plaintiff i I HARTMAN SHURR Attomeys for Plaintiff Dominic A. DeCecco, Esquire Attorney I.D. #79479 1100 Berkshire Blvd., Suite 301 P, O. Box 5828 Wyomissing, PA 19610 610-779-0772 WOORT AMERICA BANK, IN THE COURT OF COMMON PLEAS OF Plaintiff : DAUPHIN COUNTY, PENNSYLVANIA : CIVIL ACTION — LAW vs CONFESSION OF JUDGMENT SUN Y1 CHON, r , �� /, /� Defendant NO. ` V � �" / �� COMPLAINT IN CONFESSION OF JUDGMENT I The Plaintiff, Wood America Bank, is a banking corporation with an address of 7400 Front Street,. Cheltenham, Pennsylvania 19012 ("Bank" or "Plaintiff). 2. The Defendant, Sun Yi Chon, is an adult individual with an address of 227 Ewe Road, Mechanicsburg, Pennsylvania 17055 ("Defendant"). 3. On or about May 8, 2006 the Defendant executed and delivered to the Bank a Promissory Note in the original principal amount of $1,050.000.00 ( "Note "). A true and correct copy of the Note is attached hereto as Exhibit A and incorporated herein by reference, 4. The amount outstanding under the Note is as follows: Outstanding Principal Balance S 838,258.28 Accrued Interest at the default interest rate of 16% per annum. ($372.56 per diem) as of 4/24/13 S 79,905.96 Late Charges as of 4/24/13 S 4,700.1 Attorneys' Commission (10%) S 92,286.44 Total Amount Due as of 4/24/13 S 1 ,0 15, 1 50.84 Under the terms of the Note, the Plaintiff is also entitled to reimbursement for all late charges, attorneys' fees, and other costs of collection. 5. A true and correct copy of the document upon which the Defendant has authorized Confession of Judgment is attached hereto as Exhibit A and is incorporated herein by reference. 6. The Bank has not assigned the Note and is the holder thereof. 7. Judgment has not been entered on the Note in any jurisdiction. 8. Judgment is not being entered against a natural person in a consumer credit transaction. 9. The Plaintiff is authorized to enter judgment by confession against the Defendant at this time. 10. The Defendant is in default of her obligations under the terms of the Note, due to, without limitation, delinquent loan payments, failure to pay real estate taxes when due, reduction in the value of collateral real estate, and default on other obligations you owe to the Bank. WHEREFORE, the Plaintiff demands judgment against the Defendant, Sun Yi Chon, in the total amount of $1,015,150.84, together with interest from April 24, 2013 forward at the default interest rate of 16% per annum ($372.56 per diem), late charges, attorneys' fees, and collection costs. HARTM � SHURR � f By mic A. DeCecco, Esquire 1100 Berkshire Blvd., Suite 301 P.O. Box 5828 Wyomissing, PA 19610 (610) 779 -0772 Attorneys for Plaintiff I I l EXHIBIT A i i i LOAN NUMBER LOAN NAME ACCT. NUMBER NOTE DATE INITIALS Sun Yi Chon 05/08108 NOTE AMOUNT INDEX (wlMargin) INITIAL RATE MATURITY DATE LOAN PURPOSE $1.050,000,00 Cltbank, N.A. Prune 82w% 06MI/13 Commercial Rate plus 0.$00% Creditor Use Only TUX0 XNST@Dlr M CORTAI3rs A coXTZsslo9 07 JQDCICaw PROVISIOX TBAT COMITOTSa A VAIN or MORT #HT RI4 W SoxWmm MAY aAva Am AL mws Tax LMWP TO OSTAIS A JODrirrR'!PI' aDAI7raT SORRO"M w-TTRMT An YORTM AoTIes. PROMISSORY NOTE (Commercial - single Advance) DATE AND PARTIES, The date of this Promissory Note (Note) is May a, 2006. The parties and their addresses are: LENDER: WOORI AMERICA BANK 1250 Broadway New York, New York 10001 Telephone: (212) 244 -3000 BORROWER: SUN YI CHON 29 N. 2nd Street Harrisburg, Pennsylvania 17101 1. DEFINITIONS. As used in Oft Note. the terms have the following meanings: A. Pronouns. The pronouns "I: *me,' and "my' refer to each Bon'ovw signing this Note, individually and together. "You" and "Your" refer to the Lender. S. Note. Note refers to this document, and any extensions, renewals, modifications and substitutions of this Note. C. Loan. Loan refers to this transaction generally, including obligations and duties arising from file terms of all documents prepared or submitted for this transaction such as applications, security agreements, disclosures or notes, and this Note. D. Loan Documents. Loan Documents refer to aft the documents executed as a part of or in connection with the Loan. E. Property. Property is any property, real, personal or intangible, that secures mfr performance of the obligations of this Loam. F. Percent hates and race change lanitations are expressed as annualized percentages. 2. PROMISE TO PAY. For value received, I promise to pay you or your order, at your address, or at such other location as you may designate, the principal sum of $1,050,000.01) ( Principal) plus interest from May 8, 2006 on the unpaid Nricipal balance until this Note matures or this obligation is accelerated. 3. INTEREST, interest will accrue on the unpaid Principal balance of tfus Note at the initial rate of 8.250 percent (Interest Rate) until June 1, 2009, after which time it may change as described in the Variable Rate subsection. A. Default Interest Rate. it you declare a default under the terms of this Loan, including for failure to pay in full at maturity, you may increase the Interest Rate otherwise payable as described in this section. In such event, interest will accrue a Default Interest Rate. The yearty interest rate then In effect can increase to Eighteen (18.009$) percent or the legal maximum interest rate, whichever is lower, if you do not pay the loan on the due date or at maturity, whether by acceleration, default or otherwise. B. Maximum interest Amount. Any amount assessed or collected as interest under the terms of this Note will be limited to the maximum NwAJ amount of interest allowed by state or federal law, whichever is greater- Amounts collected to excess of the maximum lawful amount will be applied first to the unpaid Principal balance. Any remainder will be refunded to me. C. Accrual. interest will accrue using a counting days method that assumes equal intervals between scheduled payments. D. Variable Rate. The Interest Rate may change during the term of this transaction. (1) Index. Beginning with the first Change gate, the Interest Rate vAl be based on the following index: Cid Bank Prime Rate. The Current Index is the most recent index figure available as of 45 days before each Change Date. You do not guaranty by selecting this Index, or the margin, that.the Interest Rate on this Note will be the some rate you charge on any other bans or Gass of loans you make to me or other borrowers. If this Index is no longer available, you will substitute a similar index. You will give me notice of your choice. Bun Yi ch Nav xork 7rmiasory Pots Iats�,al,F HY/ 4XXktrikl9CCO937100005187060050506N -1996 Sauaxt syrtams, Inc.. St. Cloud, W C Pagc 1 i (2) Change Date. Each date on which the Interest Rate may change is called a Change Date_ The Interest Rate may change June 1. 2009 and every 3 months thereafter. (3) Calculation Of Change. Before each Change Date you will calculate the Interest Rate, which will be the Current Index plus 4.500 percent. The result of this calculation will be rounded to the nearest .001 percenL Subject to any limitations, this wifi be the Interest Rate until the next Change pate, The new interest Rate will become effacfive on each Change Date. The Interest Rate and other charges on this Note will never exceed the highest rate or charge allowed by law for this Note. (4) Effect Of Variable Rate. A charge in the Interest Rate will have the following affect on the payments: The amount of scheduled payments will change. 4- ADDITIONAL CHARGES. As additional consideration, I agree to pay, or have paid, the additional fees and charges requested by the tender. 5. REMEDIAL CHARGES, In addition to interest or other finance charges, t agree that I will pay these additional fees based on my method and pattern of payment, Additional remedial charges may be described elsewhere in this Note. A. Late Charge. if a payment is more than 15 days late, I will be charged 5.000 percent of the Amount of Payment or $100.00, whichever is greater. 1 will pay tht late charge promptly but only once for each late payment 6. GOVERNING AGREEMENT. This Note is further governed by the Commercial Loan Agreement executed between you and me as a part of this Loan, as modified, amended or supplemented. The Commercial Loan Agreement states the terms and conditions of this Note, including the terms and conditions under which the maturity of this Note may be accelerated. When I sign this Note, I represent to you that I have reviewed and am in compliance with the terms contained in the Commercial Loan Agreement. 7. PAYMENT. I agree to pay this Note in 84 payments. This Note is amortized over 240 payments. A payment of $8,946.69 will be due July 1, 2006, and on the 1 st day of each month thereafter. I wig make 36 scheduled payments of this amount The scheduled payment amount may then change every 3 payments thereafter. Changes in the interest Rate will not affect the scheduled payment amount during these periods. With each scheduled payment change the payment amount will be adjusted to reflect changes in the Interest Rate during the remaining term of this Note. In addition, changes to the scheduled payment amounts are subject to changes in the Interest Rate as described in the Variable Rate subsection of this Note. A final payment of the entire unpaid balance of Principal and interest will be duo June 1, 2013. Payments wig be rounded to the nearest $.01, With the final payment I also agree to pay any additional fees or charges owing and the amount of any advances you have made to others an my behalf. If the amount of a scheduled payment does not equal or exceed interest accrued during the payment period the unpaid portion will be added to, and wig be payable with, the next scheduled payment. Each payment I make on this Note will be applied first to any charges that I Owe other than principal and interest then to interest that is due, and finally to principal that is due. If you and I agree to a different application of payments, we will describe our agreement on this Note. You may change thow payments are applied In your sole discretion wittwut notice to me. The actual amount of my final payment will depend on my payment record. 8. PREPAYMENT. A full or partial prepayment of the principal prior to the fifth(5 anniversary of the closing will be subject to prepayment charge equal to two percentage (2.00 of the amount prepaid. There you may prepay the ban in whole or in part wUhout having to pay a prepayment charge. 9. LOAN PURPOSE. This is a business - purpose loan transaction. 10. DUE ON SALE 012 ENCUMBRANCE. You may, at your option, declare the entire balance of this Note to be Immediately due and payable upon the creation of, or contract for the creation of, any lien, encumbrance, transfer or sale of all or any part of the Property. This right is subject to the restrictions imposed by federal law (12 C.F.R, 581), as applicable. However, if I am in default under this Agreement, I may not sell the Inventory portion of the Property even in the ordinary course of business. 11. WAIVERS AND CONSENT. To the extent not prohibited by raw. I waive protest, presentment for payment, demand, notice of acceleration, notice of intent to accelerate and notice of dishonor. A. Additional Waiver's By Borrower. In addition, 1, and any party to this Note and Loan, to fate extent permitted by law, consent to certain actions you may take, and generally waive defenses that may be available based on these actions or based on the status of a party to this Note. (1) You may renew or extend payments on this Note, regardless of the number of such renewals or extensions. (2) You may release any Borrower, endorser, guarantor, surety, accommodation maker or any other co- signer. (3) You may release, substitute or impair any Property securing this Note. (4) You, or any institution participating in this Note, may invoke your right of set -off, (5) You may enter into any sates, repurchases or participations of this Note to any person in any amounts and I waive notice of such safes, repurchases or participations. (6) 1 agree that any of us signing this Note as a Borrower is authorized to modify the terms of this Note or any instrument securing, guarantying or relating to this Note. (7) 1 agree that you may inform any party who guarantees this Loan of any Loan accommodations, renewals, extensions, modifications, substitutions or future advances. S%w Yi Vnan Yew York Promissory Note Ins als .NY /t XXknk3900093710000510706005050A th -1996 Bankers Systama, Inc., St. Cloud, PW C Page I r B. No Waiver By Lender. Your course of dealing, or your forbearance from, or delay in. the exercise of any of your rights, remedies, privileges or right to insist upon my strict performance of any provisions contained in this Note, or any other Loan Document, shall not be construed as a waiver by you, unless any such waiver is in writing and is signed by you. 12. COMMISSIONS. 1 understand and agree that you (or your affiliate) will earn commissions or fees on any insurance. products, and may earn such fees on other services that I buy through you or your affiliate. 13. APPLICABLE LAW. This Note is governed by the laws of New York, the United States of America, and to the extend required, by the taws of the jurisdiction where the Property is located, except to the extent such state laws are preempted by federal law. 14. JOINT AND INDIVIDUAL LIABILITY AND SUCCESSORS. My obligation to pay the Loan is independent of the obligation of any other person who has also agreed to pay H. You may sue me alone, or anyone else who Is obligated on the Loan, or any number of us together, to tolled the Loan. Extending the Loan or new obligations under the Loan, will not affect my duty under the Loan and I will still be obligated to pay the Loan. This Note shall Inure to the benefit of and be enforceable by you and your successors and assigns and shall be binding upon and enforceable against me and my personal representatives, successors, heirs and assigns. is. AMENDMENT, INTEGRATION AND SEVERASILITY. This Note may not be amended or modified by oral agreement. No amendment or modification of this Note is effective unless made in wrung and executed by you and me. This Note and the other Loan Documents are the complete and final expression of the agreement if any provision of this Note is unenforceable, then the unenforceable provision will be severed and the remaining provisions will stBl be enforceable. 16. INTERPRETATION. Whenever used, the singular includes the plural and the plural includes the singular, The section headings are for convenience only and are not to be used to Interpret or define the terms of this Note, 17. NOTICE, FINANCIAL REPORTS AND ADDITIONAL DOCUMENTS, Unless otherwise required by law, any notice will be given by delivering it or mailing it by first class mail to the appropriate party's address listed in the DATE AND PARTIES section, or to any other address designated in writing. Notice loons Borrower will be deemed to ba notice to all Borrowers. I will inform you in writing of any change in my name, address or other application information. 1 agree to sign, deliver, and file any additional documents or certifications that you may consider necessary to perfect, continue, and preserve my obligations under this Loan and to confirm your lien status on any Property. 'rfine is of the essence. 18. CREDIT INFORMATION. I agree to supply you with whatever Information you reasonably request. You will make requests for this information without undue frequency, and will give me reasonable time in which to supply the inforrnation. 19. ERRORS AND OMISSIONS. I agree, If requested by you, to fully cooperate In the correction, if necessary. in the reasonable discretion of you of any and all loan dosing documents so Itud all documents accurately describe the loan between you and me. I agree to assume all costs Inducting by way of illustration and not limitation, actual expenses, legal fees and marketing losses for failing to reasonably comply with your requests within thirty (30) days. 20. CONFESSION OF JUDGMENT. Borrower hereby authorize and empowers arty attorney or the prothonotary or dark of any court in the commonwealth of pennsytvanie, or In any other jurisdiction which permits the entry of judgment by aonfesion, to appear for borrower at any time after the occurrence of an event of default in any action brought against borrower on Ilse note or the loan documents at the suit of lender, with or without-complaint or declaration filed, without stay of execution, as of any term or time, and therein to confess or enter judgment against borrower for the entire unpaid outstanding principal amount of this note and all other sums to be paid by borrower to or on behalf of leader pursuant to the terms hereof or of the loan documents and all arrearages of Interest thereon, together with all costs and other expenses and an attorney's collection commission of ten pement(10%) of the aggregate amount of the foregoing sums, but in no event less than $5,000.00, and for so doing this note or a copy hereof verified by affidavit shall be a sufficient warrant. The authority granted herein to confess judgment shall not be exhausted by any exercise thereof but shall continue from time to time and at all times until payment in full of all the amounts due hereunder. Borrower acknowledges that it understands the foregoing and that it knowingly, inteliigently and intentionally waives its right to be haard prior to the entry of such judgment and understands that upon such entry, such judgment shall become a Lien on sit real property of borrower in the eountywhere such judgment is entered and that execution may immediately be issued on the judgment to gamish, levy on or attach any personal property of borrower. I 21. SIGNATURES. By signing under seal. I agree to the terms contained in this Note. I also acknowledge receipt of a copy of this Note. I i BORROWER f I (Seat) Yi t3lan Sun Yi Chon New York trmissory trot* Ini�f alt NY/ 47LY1cnk190009 77100025SB7060050506N -1996 Sankers 5ysterus, Irc.. St. Cloud, MH C Page 3 AFFIDAVIT STATE OF SS: COUNTY OF Kim Young Bong, being duly sworn according to law, deposes and says that he is a duly authorized officer of Woori Bank America, Plaintiff herein; that he is authorized to execute this Affidavit on behalf of Plaintiff; that the facts set forth in the foregoing Complaint in Confession of Judgment are true and correct to the best of his knowledge, information and belief, and that the documents attached as Exhibits to the Complaint are true and correct copies of the originals. Kim Ybung Bong, First Vice President Sworn to and subscribed before me this =f'`3 day of , 2013. N -- otary Pu IiC MOON SOO KWON MQTARY Pusuc OF NEW ZMEY W COMMON EXPIRES FEB. 25,200 WOORI AMERICA BANK, : IN THE COURT OF COMMON PLEAS OF Plaintiff DAUPHIN COUNTY, PENNSYLVANIA : CIVIL ACTION — LAW VS. CONFESSION OF JUDGMENT SUN YI CHON, Defendant NO. ao AFFIDAVIT OF COMMERCIAL TRANSACTION k4) STATE OF SS: COUNTY OF &� Kim Young Bong, being duly sworn according to law, deposes and says that he is an authorized officer of the Plaintiff herein, and as such states that judgment is not being entered against a natural person in a consumer credit transaction. Kim Yo ng Bong, First Vice President Sworn to and subscribe before me thi day of , 2013. mvw Notary Public MOON SOO i(WON c_a NOTARY PUBLIC OF NEW JERSEY NY COAMNINION EV RES FEB. X. 2013 G'1 s r WOORI AMERICA BANK, : IN THE COURT OF COMMON PLEAS OF Plaintiff . DAUPHIN COUNTY, PENNSYLVANIA : CIVIL ACTION — LAW vs. CONFESSION OF JUDGMENT SUN YI CHON, �O Defendant NO. AFFIDAVIT OF EARNINGS /�.a ter STATE OF SS: COUNTY OF e Kim Young Bong, being duly sworn according to law, deposes and says that he is an authorized officer of the Plaintiff herein; that he is authorized to make this affidavit on behalf of Woori America Bank; and that, to the best of his knowledge, information and belief, the income of the Defendant, Sun Yi Chon, is in excess of $10,000.00 per year. l` Kim Yo *g Bong, First Vice President Sworn to and subscribed before me this day of 4 2013. �a TV Notary Public --> MOON SOO KWON NOTARY PUBLIC OF NEW JEW Ca MY COI mioN EXMS FE8. 25.2015 Co WOORI AMERICA BANK, IN THE COURT OF COMMON PLEAS OF Plaintiff DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION — LAW VS. CONFESSION OF JUDGMENT SUN YI CHON, Defendant NO. ao AFFIDAVIT OF NON- MILITARY SERVICE STATE OF SS: COUNTY OF Pit Kim Young Bong, being duly sworn according to law, deposes and says that he is an authorized officer of the Plaintiff herein, and as such states the following: 1. The Defendant, Sun Yi Chon, is not in the military or naval service of the United States or its allies, or otherwise within the provisions of the Servicemembers Civil Relief Act (50 App. U.S.C. §501 et.). 2. The Defendant, Sun Yi Ch.on, is more than 21 years of age and has a mailing address of 227 Ewe Road, Mechanicsburg, Pennsylvania 17055. 3. He makes this affidavit with due authority based upon personal investigation. Kim Young Bong, First Vice President Sworn to and subscribe i before me this 9q4 day of J:Wr? l 2013. Notary Public MOON SOO KWON c , 0 NOTARY PUBLIC OF NEW JERSEY My CoMmISSIoN ExpwM FEB. 25, 2M5 HARTMAN SHURR Attorneys for Plaintiff Dominic A. DeCecco, Esquire Attorney I.D. #79479 1100 Berkshire Blvd., Suite 301 P. O. Box 5828 Wyomissing, PA 19610 610- 779 -0772 WOORI AMERICA BANK, IN THE COURT OF COMMON PLEAS OF Plaintiff DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION — LAW VS. CONFESSION OF JUDGMENT SUN YI CHON, � � MID 3 Defendant NO. ( • ' V CERTIFICATION OF ADDRESSES COMMONWEALTH OF PENNSYLVANIA '• SS: COUNTY OF BERKS �a .. rn Dominic A. DeCecco, Esquire, being duly sworn according to law, deposes and says that to the best of his knowledge, information and belief, the addresses of the judgment creditor and the judgment debtor in the above - captioned case are as follows: Plaintiff Defendant: Woori America Bank Sun Yi Chon 7400 Front Street 227 Ewe Road Cheltenham, PA 19012 Mechanicsburg, PA 17055 i HARTMAN SHU , By . tInwr Knic A. DeCecco, Esquire Attorneys for Plaintiff Sworn to subscri sore me this n day of , 2013. Notary Public ( tw� NMALTHO ' FMNNSYLVANFA NOTARIAL SEAL JANICE M. iCRALLIS, Notoy Pu* Wyomissing Som., BeFks County My Commission June 19, 2014 HARTMAN SHURR ` t g `� �� '� Attorneys for Plaintiff Dominic A. DeCecco, Esquire 1 � AUK 2 8 Al, 10: -7 Attorney I.D. #79479 1100 Berkshire Blvd., Suite 301 U .'�1 B L R L A 1 d D C 0 i l� P.O. Box 5828 PEN N SYL AI'1A Wyomissing, PA 19610 (610) 779 -0772 WOORI AMERICA BANK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION — LAW VS. SUN YI CHON, Defendant NO. j7' 5,6 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF BERKS Dominic A. DeCecco, Esquire, being duly sworn according to law, deposes and says that he is counsel for Plaintiff, Woori America Bank, and as such states the following: 1. The judgment docketed to No. 2013 -CV- 03903 -NT, Dauphin County Court of Common Pleas, Commonwealth of Pennsylvania is valid, enforceable and unsatisfied; and 2. He makes this affidavit to the best of his knowledge, information and belief and with due authority based upon information provided to him by the Plaintiff. HARTM SHURR By: I is A. Debe quire Attorneys for Plaintiff Swo subscribed before me this of August, 2014. Notary Public MOWN- PEtItiS ifAN1A NOTARWL SEAL JANICE M. KRALLIS, Notary Public Wyom h, Berhs County My Commi ires June 19, 2018 HARTMAN SHURR 'I:! r , , [? , ; ; �) � � I Attorneys for Plaintiff Dominic A. DeCecco, Esquire Attorney I.D. #79479 1 4 A UG ea 10 U 1100 Berkshire Blvd., Suite 301 P.O. BOX 5828 Wyomissing, PA 19610 i' E N N s (610) 779 -0772 WOORI AMERICA BANK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION — LAW VS. SUN YI CHON, A r Defendant NO. AFFIDAVIT OF NON - MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF BERKS Dominic A. DeCecco, Esquire, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff herein, and as such states the following: 1. The Defendant, Sun Yi Chon, is not in the military or naval service of the United States or its allies, or otherwise within the provisions of the Servicemembers Civil Relief Act (50 App. U.S.C. § 501 et seq.). 2. The Defendant, Sun Yi Chon, is more than 21 years of age and has a mailing address of 227 Ewe Road, Mechanicsburg, PA 17055. 3. He makes this affidavit with due authority based upon information provided to him by Plaintiff. HART SHURR By , i 'c A. DeCecc , squire Attorneys for Plaintiff Sworn to�? d subscribed before me t is ?,' I day of August, 2014. Not Public OMM � I OF pgI�NSYLVANIA NOTARIAL SEAL. JANICE M. KRALLIS, Notaay Public Wyomissing Borough, Belles County My Commission Expires June 19,20`18 HARTMAN SHURR Attorneys for Plaintiff Dominic A. DeCecco, Esquire Attorney I.D. #79479 h�'J 1 1100 Berkshire Blvd., Suite 301 P.O. Box 5828 EN N F S YL Wyomissing, PA 19610 (610) 779-0772 WOORI AMERICA BANK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION — LAW VS. SUN YI CHON, Defendant NO. )V_:505q CERTIFICATION OF ADDRESSES COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF BERKS Dominic A. DeCecco, Esquire, being duly sworn according to law, deposes and says that to the best of his knowledge, information and belief, the addresses of the judgment creditor and the judgment debtor in the above-captioned proceeding are as follows: Plaintiff Defendant: Woori America Bank Sun Yi Chon 7400 Front Street 227 Ewe Road Cheltenham, PA 19012 Mechanicsburg, PA 17055 SHURR HART Y T I B i s A. DeCecco, Esquire Attorneys for Plaintiff t w oj:n to subscribed before me day of August, 14. Notary PuAc COMMOWMALTH OF PENNSYLVANIA NOTARIAL SEAL JANICE M. KRALLIS, Notary Public W miss" Borough Barks County MY tommission ExoWs June 19, 2018 WOORI AMERICA BANK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION — LAW VS. SUN YI CHON, Defendant NO. / NOTICE OF FILING JUDGMENT To: Sun Yi Chon (X) Notice is hereby given that an Exemplified Judgment in the above - captioned proceeding has been entered against the Defendant, Sun Yi Chon, in the amount of $1,015,150.84, together with interest from April 24, 2013 forward at the default interest rate of 16% per annum ($372.56 per diem), late charges, attorneys' fees, and collection costs on � '1- 2014. (X) A copy of all documents filed with the Prothonotary of Cumberland County in support of the within judgment is /are enclosed. PROTHONOTARY OF CUAN OU By: W1 � Deputy If you have any questions regarding this Notice, please contact the filing party: Dominic A. DeCecco, Esquire Hartman Shurr 1100 Berkshire Blvd., Suite 301 P.O. Box 5828 Wyomissing, PA 19610 (610) 779 -0772 (This Notice is given in accordance with Pa.R.C.P. No. 236.) j7 HARTMANSHURR 0 „ r - J'�� Attorneys for Plaintiff 0 Dominic A. DeCecco, Esquire ' hi AUG 28 ": Attorney I.D. #79479 ,Tj A 11 U 1100 Berkshire Blvd., Suite 301 F E IbER �%J LAND C 0 U"T'l P.O. Box 5828 ik Wyomissing, PA 19610 f S '-'� I i tj A (610) 779-0772 WOORI AMERICA BANK : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW VS. SUN YI CHON, Owl Defendant NO. t'S q PRAECIPE FOR ENTRY OF APPEARANCE To: Prothonotary of Cumberland County Kindly enter the appearance of Dominic A. DeCecco, Esquire and Hartman Shurr on behalf of the Plaintiff in the above-captioned proceeding and direct copies of all notices and other documents to: Dominic A. DeCecco, Esquire Hartman Shurr 1100 Berkshire Blvd., Suite 301 P.O. Box 5828 Wyomissing, PA 19610 HARTM SHURR By. Thic A. DeCecco, Esquire 1100 Berkshire Blvd., Suite 301 P.O. Box 5828 Wyomissing, PA 19610 (610) 779-0772 Attorneys for Plaintiff