HomeMy WebLinkAbout05-1871
COMMUNITY BANKS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VAN
v.
: NO. O~ - 117(
(It""ulL~'€m
GRETT A C. ZECHMAN dlb/a AARDVARK :
SIGNS, : CIVIL ACTION - LAW
Defendant : CONFESSION OF JUDGMENT
CONFESSION OF JUDGMENT
Pursuant to the authority con1ained in the warrant of attorney, the original or a cop of
which is attached to the complaint filed in this action, I appear for the Defendant and con ess
judgment in favor of the Plaintiff and against Defendant as follows:
Principal
$38,210.31
Other authorized items:
Interest to March 31, 2005
Satisfaction Fee
Prepayment Penalty
Late Charges
Attorneys' Fees
$ 577.75
$ 85.00
$ 764.21
$ 100.00
$ 1.986.86
TOTAL
$41,724.13 plus interest at the rate of $6.680
per day, through the date of payment, inclu ing
on and after the date of entry of judgment 0
the Complaint, and for other expenses, fees nd
costs to which the Plaintiff may be entitled.
Respectfully submitted,
SAlOIS, SHUFF, FLOWER & LINDSAY
Date: Lj If /or:
By:
~f . S uff, Esquire
~me CDurt ID #24848
2109 Market Street
Camp Hill, PA 17011
(717) 737-3405
Attorney for Plaintiff
COMMUNITY BANKS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V IA
v.
: NO.
GRETT A C. ZECHMAN d/b/a AARDVARK :
SIGNS, : CIVIL ACTION - LAW
Defendant : CONFESSION OF JUDGMENT
COMPLAINT FOR CONFESSION OF JUDGMENT
UNDER RULE 2951
1. The Plaintiff, Community Banks, is a financial institution organized and e . sting
under the banking laws of the Commonwealth of Pennsylvania with a principal regional ffice
located at 55 Wetzel Drive, Hanover, Pennsylvania 17331 ("Bank").
2. The Defendant, Gretta C. Zechman d/b/a Aardvark Signs, is an adult indiv dual
whose last known address is 4830 Carlisle Pike, Mechanicsburg, Pennsylvania 17050 (the
"Defendant").
3. Defendant executed and delivered to Plaintiff a Commercial Fixed Rate Promi my
Note dated August 5, 2004 (the "Note") in connection with a loan in the original principal am unt
of Forty-One Thousand One Hundred Thirty-Nine and 72/100 Dollars ($41,139.72) (the "Lo ").
A true and correct photostatic reproduction of the original No1e is attached hereto as Exhibit 'A"
and made a part hereof.
4. Defendant is in default of Defendant's obligations to make payment to Plaintif as
required in the Note.
5. Judgment is not being entered by confession against a natural person in connect on
with a consumer credit transaction.
6. There has not been any assignment of the Note.
7. Judgment has not been entered on the Note in any jurisdiction.
8. The amount due to Plaintiff as a result of Defendant's default is as follows:
a. Principal $38,210.31
b. Interest to March 31, 2005 $ 577.75
c. Satisfaction Fee $ 85.00
d. Prepayment Penalty $ 764.21
e. Late Charges $ 100.00
f. Attorneys' Fees $ 1.986.86
TOTAL: $41,724.13
WHEREFORE, Plaintiff, Community Banks, demands judgment against the Defe dant,
Grella C. Zechman d/b/a Aardvark Signs, in the amount of Forty-One Thousand Seven H dred
Twenty-Four and 13/100 Dollars ($41,724.13), plus interest at the rate of $6.6807 per day, thr ugh
the date of payment, including on and after the date of entry of judgment on this Complaint, an for
other expenses, fees and costs to which the Plaintiff may be entitled.
Respectfully submitted,
SAlOIS, SHUFF, FLOWER & LINDSAY
Date: i /s/or
BORROW~a:
'ComrhunitvBanks
COMMERCIAL
FIXED RATE
PROMISSORY
NOTE
f70~~~~~ad
Harrisburg, PA 17110
(711) 909-3400 "LENDERu
6 .500 %
Refinance existin debt
PROMISE TO PAY: For value received, Borrower promises to pay to the order of lender the principal amount ot :Forty One Thousand One
Hun<tt8d Thirtv Nine and 12/100 Donar8 ($ 41.139.72 ) plus
interest on \he unpaid prinoipal balanoe at the rate snd in the manner described below, until aU amounts owing under tl1ls Note are paid in full. All amounts
receiv6<l by lel"odel shall be applied tlrst to accruoo, unpaid interest, then to unpaid principal, and then to any late charges and expenses, or in any other order
as determined by Lerld9i, in l&rrd&r's sofe discrellon, as permitted by law.
INTEREST RATE: Intarest s1ia" be computed on the basis of the actual number of dayS over 360 dayS per year. Interest
on this Note shall be oalculated and payable at the fIxed rate of 6 . 500 % per annum.
DEFAULT RATE: Ifthere is an Event of Default u!'1der this Note, th& Lander may, in its discretion, increase the Inlerest rate on this Note to: Rate. in
effect at time of default D1U9 two oercent {2%}
or the maximum interest rate Lender is permitted to charge by law, wh\ohav&r is less.
PAYMENT SCHEDULE: Borrower shall pay the principal and il'lterest acccrO!ng to the follOWing sohedule:
S9 payments of $805.74 beginning September 05, 2004 and continuing at monthly time intervals
thereafter. A final payment of the unpaid principal balance plus accru~d interest is due and
payable on Augu~t 05, 2009.
PREPAYMENT: This Note may be prepaid in part or in full on or before its maturity date-I!] with 0 without penalty. If this Nole contains more than
one installment, any partial prepayment wJll not affect the due date or the amount of any subsequent instailment, unless agreed to, in WritJflg, by
Borrower and Lender. If this Note is prepaid in full, there will be 0 A mInimum finance charge of $
o A prepayment penalty of :
Borrower shall pay a prepayment penalty equal to 2.00% of the amount prepaid if prepaid by a
third party. Prepayments made by Borrower are acceptable.
LATE CHARGE: If a payment Is raceived more than 10 days late, Borrower will be charged a lale Charge of: 0
~aid latapayment;n$ ;IKJ 5.00 %ofthe ul'lpa\d late payment or$50.00
U less,aspermittedt.'Y law. No more than one late charge will be imposed cn any single payment orporticl'l of any payment.
"loot the
whichever is [!] greater
SECURITY: To secure the payment and performance of obligations incurred under this Note, Borrowar grants lendaT a secUrity interest in all of Borrower's
right, tille, and interest in all monies, instruments, savings, checking, share and other aooounts of Borrower (eXCluding lAA, Keogh. trust accounts and olher
aocounts subject to lax penaJtielS if so assJgned) that are now or In the future 11'1 Lender's cuslody or control. [J If checked, the obligallons under this Nota are
also secured by the collateral desoribed in any security instrument(s) executed In ccnnection with thIS Note, and any c::ollateral described In any other security
instrumant(s) securing this Note ot aU of Borl'O'Her's obligations,
CHECK PROCESSING FEE: If a check for payment ia retumed to Lander lor any f68.SOI'\ (lot axample, because there are Insuffioient funds in Borrowar's
checking aocount), Le.rn:ier will assess a check processing fee of $ 35. 0 0 , which shall be added to the principal "Dalance.
RENEWAL: 0 If checked, this Note is a renewal, but TlOt a sallsfacUon, of Loan Number
WARNING: HUU Bt:.!-OHt:. SIGNINU - YOU AHt: WAIVING IMPUHI ANT HIUHl S
net IF CHECKED, AS A MATERIAL INDUCEMENT TO lENDER TO MAKE THE lOAN EVIDENCED BY "THIS NOTE. BORROWERIRREVOCABL Y AUTHORlZESANO EMPOWERS
;my ATTORNEY OR THE PROTHONOTARYOR CLERK OF AN'f COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR asEWHERE, TO APPEA,RAS 1\TTORNEY R)R
BORROWERIN ANY ACTION BAOuaHT BY LENDER AFTER BORROWER'SOEFAULT UNDER THIS NOTE OR ANY OTHER LOAN DOCUMENT, AND TO CONFESS JUDGMENT
AOAINST BORROWERFORALL SUMS Due UNDERlH1S NOTE OR AN'( OTHER LOAN DOCUMENT, AND FORAU. ACCRUED INTEREST ON THOSE AMOUNTS, COST OF surr,
AND ATTORNEY FEES, TOGeTHER WITH INTEREST ON ANY JUDGMENT, AT THE RATE OF lNTEREST SPECIFIED IN THE NOTE AFTER DeFAULT. FROM THE ENT'RY OF
SUCH JUOGMENT UNTIL THe FUll AMOUNT DUE lENDe-R IS ACTUALLY RECEIVED. THIS NOTE, OR A COPY VERIFIED BY 1\FFlOAVIT, WILL BE A SUFfiCIeNT WARRANT.
THE AUTHORITYGRANTIIDHEREJN MAY BE EXERCISED AS NEEDEO FRQMTIME TQTIME, AS OFTEN AS NECESSARY. UNTIL RECEIPT OF PAYMENT IN FULL OF AtJ. SUMS
OUELENDER.
BORROWERKNOWrNGl Y, INTENTIONALLY AND VOLUNTAAIl Y, 1\fTEFI CONSULTATION WITH INDEPENDENT COUNsa, UNCONDrnONAlLYWAlVE5 Am AND AU flIGHTS
TO DUE PROCESS BORROWER HAS OR MAY HAVE UNDEATHE CONSTITUTIONS AN{) LAWS OF THE UNITEO STATES AND OFTHE COMMONWEALTH OF PENNSYl.VANlA,
EXCEPT THE AIOHT TO AN( NOTICE AND/OR HE1\A1NO REQUIRED UNDER APPliCABLE LAW WITH RESF'ECT TO THE EXECUTION OF ANY CONFESSED JUDC3MENT.
BORROWERFURTHEAUNDERSTANDS THAT UPON 80RROWER'SDEFAULT AND CONFESSION OF JUDGMENT. THIS WAVIER AlLOWS LENDER TOIMMEOIATaY EXECUTE
UPON AND S8ZE. ANO Sell I\NY OF BORROWER'S PROPERTY WITHOUT PRIOR NOTICE OR OPPORTUNITY FOR HEARING, EXC'EPT ANY NOTICE ANO/OR HEARINC3
REOUlRED UNDER APPliCABlE LAW WITH RESPECT TO THE EXECUTION OF THE CONFESSED JUDaMeNT, iN ORDER TO SATISFY OR SECURE ALL SUMS DUE.
THE PERSONS SIGNING BELOW ACKNOWLEDGETHATTHEY HAVEREAQ,UNOERSTAND,ANOAGREETO THE TEAMS AND CONDITIONS OF THIS NOTE.
iNCLUDING THE PROVISIONS ON THE REVERSE SIDE, AND FURTHER ACKNOWLEDGE ~ECEIPT OF AN EXACT COPY OF THIS NOTE.
IN WlTNESSWHEREOF,the underl!ligned hae/halle caused '!his instrument to be executed as ill sealed Jnstrument this 5th day of Auaust. 2004
BORROWER: Gretta C Zechman BORROWER:
~d/b/a Aardvark Signs
_ ~~_~C! --a,.--L, (Seal)
Gretta za~~-"
(Seal)
BORROWER:
BORROWER:
(Seal)
(Seal)
BORROWER:
BORROWER:
(Seal)
(Sea~
BORROWER:
BORROWER:
(SoaJ)
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TERMS AND CONOmONS
1. EVENTS OF DEFAULT. An EVefll of De' .vjll OCCUr under this Note in lh$ event that Borre", .ny guarantor ar any other thIrd party pledging
collatsljiIllo secure this Nole:
(a) faUs to make arlY payment on this Note or any other indebtedness to Lender when due;
(b) jails to Qr'l'offil any obUgatiol'l Of breaches any warranty or covenant to Lender contained in this Nate, any secUrity instnJment, or any other
present or futWB wn"en agreement regarding \h\s or any other Indebtedness of Borrower to Lender;
(e) proviues or causes any false or misleading signature or ~resentation to be provided to Lender;
(d) sells, conveys, or transfers rights in any collateral securing this Note without the written approval of Lender; destroys, loses or damages such
collateral in any material respect or subjects SUch collateral to seizure, confi$catlon or condemnation;
(e) has a gamishmenl, judgment, tax levy, attachment or lien entered or served against Borrower, any guarantor, or any third party pledging
collateral to secure this Note or any of their property;
(f) dias, becomes lega.ily incompatant, is dissolved or tenninated, cesses to operate Its bUsiness, becomes insolvent, makes an assignment for the
benefJ! of creditors, fails to pay debts as they become due, or becomes !he subject of any bankruptcy, insolvency or debtor rehabmtation
proceeding;
(g) rails to provide Lender evldenoe of satisfaotory financial condition;
(h} has a majority of its outstanding voting securities sold, transferred or conveyed to any person or entity other than any person or enlity that has
the majortty ownership as of the date 01 the execution of this Note; or
(i) causes Lander to deem itself ins&Cl.lTe due 10 a significant decline in the value of any real or per80nal projl6rty BeCUling paymant at this Note, or
Lender in good faith, believes the prospect of payment or performanca Is impaired.
2. RIGHTS OF lENDER ON EVENT OF DEFA.ULT. lfthere is an Event of Default under this Note, Lender will be entitled to exerclaeone or more of the
following remedies without notice or demand (axcept as fequired by law):
(a) to declare the principal amount plus accrued interest under this Note and all other present and future obligations of Borrower immedlal$ly due
and payable in tun, such acceleration shail be automatic and immediate if the Evant of Default is a filIng under the Bankruptcy Code;
(b) to coUee! the outstanding obligations ot Borrower with or without resorting to judlolal process;
(c) to oease makJng advances uMer \his Note cr any other agreement betw"een Borrower and lender;
(d) to taka possession of any oollateral in ant manner permittad by law;
(e) to require Borrower to deliver and make available ro lender any collateral at a place reasonably convenient to Borrower and Lender,
(f) to sell, lease or otherwise dispose of any collateral and co~ect any deflciency balance with or without resorting 10 legal procass;
(g) to sel-off Borrower's obligations against any amounts due to Borrower includIng, but not limited to, monies, instruments, and deposit accounts
maintained wilh lender; and
(hl to exeroise all other lights ava~!I.ble to lander under any other written agreemantcr applicable law.
Lander's rights are cumulative a.nd may be exeroised together, separately, and in any order. Lander's remedies under this paragraph are in addition to
those availabi6 at common law, including, but not limited to, the right at sel-off.
3, DEMAND FEATURE. 0 If checked, this Note contains a demand feature. Lender's right to demand paymant, at any Ume, and from time to time,
shaJf be in lender's sole and absolute dlscretion, whether or not any default has occurred.
4. ANANCIAL./NFORMA TlON. Borrower will at all times keep proper books of record and account in which full, true and correct entties shall be made
In aCC(lrdanoe with gsnerally accepted accounting prinoiples and will dellver 10 lender, within ninety (90) days after the end of ~ch fiscal year of
Borrower, a copy of the annual f1nanoial statements of aorrower relating to such fiscal year, such statements to include (JJ the balanoe sheet of
Borrower as at the end of such fiscal year and (Ii) the related income statement, statement of retained earnings and statement of cash flow of Borrower
for such fiscal year, prepared by such certified plJbllC accountants as may be raasonably satisfaotory to Lender. Borrower also agrees to deliver to
lender within lIfte&l\ {15) days alter filing same, a copy of Borrower's income tax returns and also, from time \0 time, such other flnanoial information
witt1 respect to Borrower as Lander may TflqUest
5. MODIFICATION AND WAIVER, The modification or waiver of any of Borrower's obligations or Lander's fights I.lnd91' this Nole must ~ contained in
a writing signed by Lender, Lander may partorm any of Bcrrower's obligations or delay or fail to exercise any of its rights without causing a waiver of
those obligations or rights. A waiver on one occasion will not constitute a waiver on any other occasion. Borrower's obligations under this Note shall
not be affected if Lander amends, compromises, exohanges, falls to eJeercisa, impairs or releases any of lt1e obligations DEilonging to any co-borrower
or guarantor or any of its rights against any oo.borrower, guarantor, tha collateral or any other property securing the obligations. Lender may accept
and apply ohecks and other Instruments marked 'Paid in Full' or with a similar phrase de,scrlbing a payment as full satisfaction of the obligations
incurred under thls Note, wilhout being bound by that language and without waiving any rights to payment of all amounts owing under this Note.
6. SEVERA.BIUTY. II any proVision of this Note Is invalid, jllegal or unenforceable, the validIty, legalily, and enforceability of the remaining provisions
shall not in any way be affected orimpalred thereby.
7. ASSIGNMENT. Borrower agrees not to assign any of Borrower's rights, remedies or obUgatlons described In this NOI$ without the prior written
consent of Lander, wNch cm,eent may be withheld by Lender in its sole discretion, Sorrower agrees that l..al'Ider is eJ1titlecl to assign soml!! or all of Ita
rights and remedies described in this Note wIthout notice to or thlt prior consent of Borrower.
S, NOnCe. Any notice or olher communication to be provided to Borrower or Lander under this Note shall be in writing and sent to the parties at the
addresses described in this Note or such other addreas as the partles may designate in writing from time to time.
9. APPUCABLE LAW. Interest, lr\cluding rates, fees and charges which oompensate Lander tor the exl$nsion of cradlt to Borrower under this Note or
lor making the line of credit available to Borrower, or which compensate lender for any default or breach by Borrower of the terms and conditions of
this Nate, shall be governed by federal law and the laws of the state- of pannsv 1 vania . All cther tel1Tl8 and conditions
of this Nota shall be governed by the laws of the state ofPennsvlvania . unless othefW'ise preempted by faderalllJw,
Uruess appncablelaw provides otherwise, Borrower consents to the iurisdictlon and "anIJe of arry court located in Pennsvl vania
seiected by Lender, In its discretion, in the evant of a legal proceeding under this Note.
10. COLLECTION COSTS. To the axtent permJlted by law, Borrower agrees to pay Lerlder'e reasonable fees and oosts. including, but not limited to,
fees and costs 01 attomeys and other agent9 (including without limitation paralegals, clerks and consultants), whe1her or not such attorney or agent is
an employee of Landar, which are Incurred by Lender in collecting any amount due or enforcing any right or remedy under 1his Note, whether or not
suit is brought, inoludlng, but not limited to, aU fees and costs incurred on appeal, In bankruptcy, and for post-judgment collection actkms.
11. MISCELLANEOUS. This Note is being executed primarily for commercial, agricultural, or business pU']JOs9$. Borrower and \..ender agree that
time is of the assence. Borrower agt8ElS to make all payments to lender at any address deslgnated by lender and in lawful United States currency.
Borrow@r and any person who endorses this Note waives presentment, demand for payment, notlae of dishonor and protest and furthe.r waives any
right to require Lender to proceed against anyona else before proceeding against Borrower or said person, All references to Borrower in this Note shell
lnt:ltlde all of the parties signing this Note, and ltlis Note sI1alJ be bindIng upon the keil'9, successors and a.ssigns of Borrower and Lender. If there is
mare than one Borrower their obligations under lt1is Note shalt be joint and saveraJ. Informatton concerning thla Nola may be reported to credit
reporting agencies and wm be made ll.vallable when requested by proper fegal process. This Note rap~ts \he complele and Integrated
understandIng between Borrower and Lander l'agarolng the terms hereof,
12. JURY TRIAL WAIVER. LENDER AND BORROWER HEREBY WAIVE ANY RIGHT TO A TRIAL BY JURY IN ANY CIVIL ACTION ARISING OUT
OF, OR BASED UPON, THIS NOTE OR ntE COLLATERAL. SECURING THIS NOTE.
13. AOOmONAL TERMS:
LPPACOMMiPJolv1fi.HilM(\d.Co. {~4100} (500)ll37.J"799
.
.
COMMUNITY BANKS,
Plaintiff
v.
GRETTA C. ZECHMAN d/b/a AARDVARK
SIGNS,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNfY, PENNSYLV A
: NO.
: CIVILACTION-LAW
: CONFESSION OF JUDGMENT
VERIFICATION
I, Betty A. Sordon, hereby verilY that the statements made in the foregoing Complaint
and correct to the best of my infonnation, knowledge and belief I understand that false stat ents
herein are made subject to the penalties of] 8 Pa. C.S. Section 4904, relating to unsworn falsifica . on to
authorities.
Date:? ))r
COMMUNITY BANKS
By:
~,~
B 1\. Sordon
Administrative Assistant
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COMMUNITY BANKS,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL NIA
: NO. O~ -IF?I eULL'/0
GRETT A C. ZECHMAN dlb/a AARDVARK
SIGNS,
Defendant
: CIVIL ACTION - LAW
: CONFESSION OF JUDGMENT
NOTICES IN CONNECTION WITH JUDGMENTS BY CONFESSIO
REQUIRED BY 42 Pa. C.S.A. S 2737.1 (Act 105 of2000)
To: Gretta C. Zechman dlb/a Aardvark Signs
Pursuant to 42 Pa. C.S. S 2737.1. please take notice that the Plajntiff in this matt r has
entered a judgment by confession against you in the amount of$41,724.13.
You are entitled to file a petition to "strike" or "open" the judgment. In order to 0 so,
you must promptly file a petition with the Court of Common Pleas of Cumberland C unty,
Pennsylvania, as required by Rule 2959 of the Pennsylvania Rules of Civil Procedure. Yo will
file a petition by leaving it with the courts or Prothonotary at the courthouse in C lisle,
Cumberland County, Pennsylvania.
A petition js a formal statement of your reasons for challenging the judgment. You ust
include the names of the parties at the top of the first page and the case number, which is s own
above. The petition must state your reasons for challenging the judgment js a separate num red
paragraphs. You have to sign the peti1ion and include a sworn statement at the end 0 the
document verifying that the facts you state in the petition are true and accurate. You will ive
any defenses and objections not included in your petition to strike or open. You must ther ore
make every effort to raise all possible issues and defenses in your petition to strike or ope III
order to avoid waiving any claims.
If you elect to file a petition, it must meet the requirements of Rule 2959 of the Rule of
Civil Procedure. A full copy of Rule 2959 is attached to this Notice. You may also hav to
comply with local rules of procedure in effect in the county where the judgmen1 was entered.
If you do not file a petition challenging 1he judgment, the Plaintiff may take step to
collect on the judgment by askjng the Sheriff to seize your assets. You may have other rig ts
available to you other than as set forth in this notice. You should take this paper to y ur
lawyer at once. If you do not have a lawyer, go to or telephone the office set forth bel w.
This office can provide you with information about hiring a lawyer.
If you cannot afford to hire a lawyer, thjs office may be able to provide you w th
information about agencies that may offer legal services to eligible persons at a reduced ee
or no fee.
,
Cumberland County Bar Association
32 South Bedford Street
Carlisle, P A 17013
(717) 249-3166 or 1-800-990-9108
Corporations may be unable to represent themselves in court. Ifthe defendants in lude a
corporation, the corporation must appear through an attorney if it intends to challen e the
judgment.
You may receive other papers and notices regarding the judgment. Those other pa ers do
not negate or override this Notice. Likewise, this Notice is not intended to and does not egate
any of the notices or information obtained in other papers that may be served upon you.
We reiterate that you are required to act promptly if you wish to seek relief fro the
judgment. Under certain circumstances, you have only 30 days in which to file a petitio after
papers are served on you. Even if the 30 day rule does not apply, you must act promptly in rder
to protect your interests. Failing to act in a timely manner will render you unable to chal enge
the judgment at a later time.
Pursuant 1040 Pa. C.S.A. Section 2737.1, if you have been incorrectly identified an had
a confession or judgment entered against you, you are entitled to costs and reasonable aft rney
fees as determined by the court.
Respectfully submitted,
Date:;jc;)C-
& LINDSAY
By:
I-?eof; . huff, Esquire
uupreme Court ID #24848
2109 Market Street
Camp Hill, PA 17011
(717) 737-3405
Attorney for Plaintiff
.
Pennsvlvania Rule of Civil Procedure 2959 - Striking: off Judl!ment
(a)(1) Relief from a judgment by confession shall be sought by petition. Ex ept as
provided in subparagraph (2), all grounds for relief whether to strike off the judgment or open
it must be asserted in a single petition. The petition may be filed in the county in wh ch the
judgment was originally entered, in any county to which the judgment has been transferre or in
any other county in which the sheriff has received a writ of execution directed to the sh riff to
enforce the judgment.
(2) The ground that the waiver of the due process rights of notice and hearing w s not
voluntary, intelligent and knowing shall be raised only
(i) in support of a further request for a stay of execution where the court h s not
stayed execution despite the 1imely filing of a petition for relief from the judgmen and
the presentation of prima facie evidence of a defense; and
(ii) as provided by Pennsylvania Rule of Civil Procedure 2958.3 or Rule 297 .3.
(3) If written notice is served upon the petitioner pursuant to Rule 2956.1(c)(2) or ule
2973.1(c), the petition shall be filed within thirty days after such service. Unless the defen ant
can demonstrate that there were compelling reasons for the delay, a petition not timely filed all
be denied.
(b) If the petition states prima facie grounds for relief the court shall issue a rule to s ow
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 Ie
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 petit on
or answer.
(d) The petition and the rule to show cause and the answer shall be served
provided in Rule 440.
(e) The court shall dispose of the rule on petition and answer, and on any testimon ,
depositions, admissions and other evidence. The court for cause shown may stay proceedings n
the petition insofar as it seeks to open the judgment pending disposition of the application 0
strike off the judgment. If evidence is produced which in a jury trial would require the issues
be submitted to 1he jury the court shall open the judgment.
(f) The lien of the judgment or of any levy or attachment shall be preserved while th
proceedings to s1rike off or open the judgment are pending.
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL
: NO. 05' _ /f71 Il-(
L'{VL'
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COMMUNITY BANKS,
Plaintiff
GRETTA C. ZECHMAN dlb/a AARDVARK :
SIGNS, : CIVIL ACTION - LAW
Defendant : CONFESSION OF JUDGMENT
NOTICE UNDER RULE 2958.1
OF JUDGMENT AND EXECUTION THEREON
NOTICE OF DEFENDANT'S RIGHTS
TO: Gretta C. Zechman dlb/a Aardvark Signs
A judgment in the amount of $41,724.13 has been entered against you and in favor 0 the
plaintiff without any prior notice or hearing based on a confession of judgment contained in a
written agreement or other paper allegedly signed by you. The sheriff may take your mon or
other property to pay the judgment at any 1ime after thirty (30) days after the date on which this
notice is served on you.
You may have legal rights to defeat the judgment or to prevent your money or property u m
being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGME T
AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATEN
WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEG
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO N
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. T
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or 1-800-990-9108
Date: L(};~ ~
Respectfully submitted,
SAlOIS, SHU~F,!~~~ & L
By: /1 ;/
Gesdfh?y. uff, E~uire
SuPreme 000 ID,Af24848
2109 Market Street
Camp Hill, PA 17011
(717) 737-3405
Attorney for Plaintiff
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COMMUNITY BANKS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V
v.
: NO. 05 -IF?I
GRETT A C. ZECHMAN d/b/a AARDVARK :
SIGNS, : CIVIL ACTION - LAW
Defendant : CONFESSION OF JUDGMENT
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance on behalf of Plaintiff, Community Banks.
Papers may be served at the address set forth below.
Geoffrey S. Shuff, Esquire
SAlOIS, SHUFF, FLOWER & LINDSAY
2109 Market Stree1, Camp Hill, P A 17011
(717) 737-3405 (fax) 737-3407
Respectfully submitted,
SAlOIS, SHUFF, FLOWER & LINDSAY
DM,4k-
By:
. huff, Esquire
~me ourt 10 #24848
2109 Market Street
Camp Hill, PA 17011
(717) 737-3405
Attorney for Plaintiff
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COMMUNITY BANKS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL ANIA
v.
: NO. OS- - JI?!
Ciuil ~~
GRETT A C. ZECHMAN dlb/a AARDV ARK :
SIGNS, : CIVIL ACTION - LAW
Defendant : CONFESSION OF JUDGMENT
CERTIFICATE OF ADDRESSES
I hereby certifY that the precise address of Plaintiff, Community Banks, is 55 Wetzel rive,
Hanover, Pennsylvania 17331; and that the last known address of the Defendant, Gre a C.
Zechman dlb/a Aardvark Signs, is 4830 Carlisle Pike, Mechanicsburg, Pennsylvania 17050.
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LINDSAY
Date: '/ h ftC::
By:
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COMMUNITY BANKS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL ANIA
v.
: NO. OS - inf
C~u;L ~ I
GRETT A C. ZECHMAN dlb/a AARDVARK :
SIGNS, : CIVIL ACTION - LAW
Defendant : CONFESSION OF JUDGMENT
AFFIDAVIT OF NON-MILITARY SERVICE
TO THE PROTHONOTARY:
I do certiJy, to the best of my knowledge, that the Defendant, Gretta C. Zechman, n the
above-captioned action is not presently on active or nonactive military status.
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LINDSAY
Date: if flue::
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COMMUNITY BANKS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V NIA
v.
: NO. Of> - 117 (
(JuLL IVL\
GRETT A C. ZECHMAN dfb/a AARDVARK :
SIGNS, : CIVIL ACTION - LAW
Defendant : CONFESSION OF JUDGMENT
To: Gretta C. Zechman dfb/a Aardvark Signs
You are hereby notified that on fiflLL-( , I \ , 2005, judgment by confessi n was
entered against you in the sum of $41,724. 3 in the above-captioned case.
DATE:
4 If( I~
~
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF Y DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHON THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Stree1
Carlisle, P A 17013
(717) 249-3166 or 1-800-990-9108
I hereby certity that the following is the address of the defendant stated in 1he certifi ate of
residence:
Grella C. Zechman dfb/a Aardvark Signs
4830 Carlisle Pike
Mechanicsburg, P A 1705
.
A, Gretta C. Zechman d/b/a Aardvark Signs
Por este medio sea avisado que en el dia de de 2005, un fallo por admi ion fue
registrado contra usted por la contidad de $41,724.13 del caso antes escrito.
Fecha: el dia de de 2005
Protonotario
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, A Y A
EN PERSONA A LLAME POR TELEFONO A LA OFICINA CUY A DIRECCI N SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONS GUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or 1-800-990-9108
Por es1e medio certifico que 10 siguiente es la direccion del demandado dich en el
certificado de residencia:
Gretta C. Zechman d/b/a Aardvark Signs
4830 Carlisle Pike
Mechanicsburg, P A 17050
A
SHERIFF'S RETURN - NOT FOUND
; >
CASE NO: 2005-01871 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COMMUNITY BANKS
VS
ZECHMAN GRETTA C DBA AARDVARK
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
ZECHMAN GRETTA C D/B/A
AARDVARK SIGNS
but was
unable to locate Her in his bailiwick. He therefore returns the
NOTICE UNDER RULE 2958.1 ,
OF JUDGMENT & EXECUTION THEREON
, NOT FOUND , as to
the within named DEFENDANT
, ZECHMAN GRETTA C D/B/A
AARDVARK SIGNS
4830 CARLISLE PIKE
MECHANICSBURG, PA 17050
NO SUCH ADDRESS. SERVICE WAS ATTEMPTED AT 5225 SIMPSON FERRY RD
MECHANICSBURG. HER HOME ADDRESS IS 121 KEITER RD HALIFAX, PA 17032.
BELIEVED TO HA.VE FILED BA.NKRUPTCY.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
Postage
18.00
9.62
5.00
10.00
.37
42.99
So answeI'El: .., ../ ,//. ./
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R. Thoma~lne
Sheriff of Cumberland County
SAIDIS SHUFF FLOWER LINDSAY
OS/20/2005
Sworn and subscribed to before me
this
.2'f~
day of 7'" ']
/
Jvto::, A. D.
iR Q . 1
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Pr onotary I~
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COMMUNITY BANKS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 0<;"-l671 Ctv,1 Te,(Y\
v.
GRETT A C. ZECHMAN dfb/a AARDVARK :
SIGNS, : CIVIL ACTION - LAW
Defendant : CONFESSION OF JUDGMENT
NOTICE UNDER RULE 2958.1
OF JUDGMENT AND EXECUTION THEREON
NOTICE OF DEFENDANT'S RIGHTS
TO: Gretta C. Zechman dfo/a Aardvark Signs
A judgment in the amount of $41,724.13 has been entered against you and in favor of the
plaintiff without any prior notice or 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 this
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 THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFOR..lVlA TroN ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HlRE A LAWYER, THIS OFFICE MAYBE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland COI.Ulty Bar Association
32 South Bedford Street
Carlisle, P A 17013
(717) 249-3166 or 1-800-990-9108
Date: 7J;~C;
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2005-01871 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COMMUNITY BANKS
VS
ZECHMAN GRETTA C DBA AARDVARK
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
ZECHMAN GRETTA C D/B/A
AARDVARK SIGNS
but was unable to locate Her
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
County, Pennsylvania, to
serve the within NOTICE
30th , 2005 , this office was in receipt of the
On June
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Dauphin Co
Postage
18.00
9.00
10.00
33.75
.74
71.49
06/30/2005
SAIDIS SHUFF
So answ,e_r_"s_~: , ~~""'>""":~
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R. Thomas Kline
Sheriff of Cumberland County
FLOWER LINDSAY
Sworn and subscribed to before me
this i.'!::- day of ~
;J.(J/)(,. A.D.
~L- Q ~,-DP,., ~
Prothonotary
In The Court of Common Pleas of Cumberland County, Pennsylvania
Cmmunity Banks
VS.
Greta C. Zechman d/b/a A.ardvark Signs
No.
05-1871 civil
Now,
June .,3. 2005
, I, SHERlFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Dauj;hin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
r~ :.,<:~
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
,20 ,at
o'clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this day of , 20_
COSTS
SERVICE '
MILEAGE
AFFIDAVIT
$
$
@ffb::e of t1p~ ~4priff
William T. Tully
Solicitor
J. Daniel Basile
Chief Deputy
Mary Jane Snyder
Real Estate Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 1710 I
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
COMMUNITY BANKS
vs
County of Dauphin
ZECHMAN GRETTA C
Sheriff's Return
No. 1010-T - -2005
OTHER COUNTY NO. 05-1871 CIVIL
I, Jack Lotwick, Sheriff of the County of Dauphin, State of
Pennsylvania, do hereby certify and return, that I made diligent
search and inquiry for ZECHMAN GRETTA C
D/B/A AARDVARK SIGNS
the DEFENDANT named in the within NOTICE OF JUDGEMENT/EXECUTION,RL.2958.1
and that I am unable to find him/her in the County of Dauphin, and
therefore return same NOT FOUND, June 24, 2005
DEFENDANT HAS FILED BANKRUPTCY
NK: BK1-05-03866 FILED 6/9/05
IN THE MIDDLE DISTRICT OF PENNSYVANIA
Sworn and subscribed to
jR~
before me this 24TH day of JUNE, 2005
Sheriff of Dauphin County, Fa.
~&J
By
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept I, 2006
Deputy Sheriff
Sheriff's Costs:$33.75 PD 06/06/2005
RCPT NO 207512
Ln.& 1.L,<t"lLU'l-'O
The Wiley Group
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[:~m(' PAM. I VI - V~.6. Nolie"Olliling
United Slates Banko-ullley C"urt
Middle IJistrict ofl',mnsJlvanir.
Notice of B'H krnptcy Case Filing
A bankruptcy c ,se concerning tbe debtor(s) lisled below was
lik,1 nnder eba iter 7 orlhe United Slates Bankruptcy Code,
entered on 06/0 112005 al 5:0S PM and (lied on 06/0912005.
Gretla C. Zed man
4830 Carlisle P kc
Mcehaniesburg, l' A 170S0
SSN: xxx-xx-3' 81
pka
Grella Charm: Inne I'e"penl
dba
Aardvarl, Sil4n ;
The ease was I led by ilK debtor's aHorney:
Timothy .J COl(an
Wiley, Lenox, ::olgan and Marzzacco. PC
130 West ChUl:h Street, Suite 100
Dillsburg, I' ^ 70] <)
717432-9h66
The case was as, igned case number 05.3866.
.rhe filing of a hi nkruptcy case 3utornahcally stays ce)1,ain ilclions against the debtor and I,he debtor's
property. If you ,Hemp\ \0 collect a debt or take otber action ill violation orthe Bankruptcy ('ode, you
may be penalize. .
If you would lib 10 view Ihe bankruptcy pctition and other documents filed by the debtor, they arc
available at onr J Wernet home page hl1p:l/www.pamh.uscourls.grw/ or atlhe Clerk's Office, V,S.
Bankruptcy Cou L Ronald Reagan Federal Bnilding, PO Box 90R, Harrisburg, PA I7IOS.
You may be a cr ditor ofthc debtor. If so, yon wiI! receive an additional no\ice fr0111 the court selling
forth imrortant c :;:adJincs.
Arlene Byers
Clerk, lJ.S.
Bankrnptcy Court
f~____.J>ACE~~;:I'~i~; (~cJ;tcr - .., - -1
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file'//CIECF\ZE 'II MAN( ;\I'iled I Compkle}\EcfNoliccOIFiling ~005.()6.01)(1I).i)504pm.htm 61912005
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filc://C:\ECF\7E ,:HMANG\Filed{ Complete 1 \Eel' N,,';ccOfT'i ling 2005-06-09(l:iI0504pm.hlm 6/<)(2005
COMMUNITY BANKS,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No.0<;:"-t211 CtvII leon
GRETIA C. ZECHMAN d/b/a AARDVARK:
SIGNS, : CIVIL ACTION - LAW
Defendant : CONFESSION OF JUDGMENT
NOTICE UNDER RULE 2958.1
OF JUDGMENT AND EXECUTION THEREON
NOTICE OF DEFENDANT'S RIGHTS
TO: Gretta C. Zechman d/b/a Aardvark Signs
A judgment in the amount of $41,724.13 has been entered against you and in favor of the
plaintiff without any prior notice or 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 this
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 THIS 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or 1-800-990-9108
Date: L.( /; ~ c; By:
TRUE COPY FROM RECORD
.. t~v wilSfltlll. i here urlto set my hMi
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COMMUNITY BANKS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 05-1871 CIVIL TERM
GRETT A C. ZECHMAN dfb/a AARDVARK:
SIGNS, : CIVIL ACTION - LAW
Defendan1 : CONFESSION OF JUDGMENT
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-captioned action settled, discon1inued and ended with prejudice.
Respectfully submitted, ,
R & LINDSAY
SAID
Date: December 27,2005
By:
Matthew J. Eshefman, Esquire 1D #72655
2109 Market Stree1, Camp Hill, P A 17011
(717) 737-3405 (fax) 737-3407
Attorneys for Community Banks
"
COMMUNITY BANKS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 05-1871 CIVIL TERM
GRETT A C. ZECHMAN d/b/a AARDVARK
SIGNS,
Defendan1
: CIVIL ACTION - LAW
: CONFESSION OF JUDGMENT
CERTIFICATE OF SERVICE
I, Matthew J. Eshelman, Esquire, of the firm of Saidis, Shuff, Flower & Lindsay, hereby
certify 1hat I this day served a true and correct copy of the Praecipe on Behalf of Communi1y Banks
upon the parties listed below via electronic mail or United S1ates Mail, postage prepaid, addressed
as follows:
Timothy J. Colgan
Wiley, Lenox, Colgan and Marzzacco, PC
130 West Church Stree1, Suite 100
Dillsburg, P A 17019
(Attorney for Defendant)
Gretta C. Zechman
121 Keiter Road
Halifax, PA 17032
Respectfully submitted,
SAIDI
L_
Date: December 27, 2005
By:
Matthew J. Eshelman, Esquire II> #72655
2109 Market Street, Camp Hill, PA 17011
(717) 737-3405 (fax) 737-3407
Attorneys for Community Banks
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