HomeMy WebLinkAbout01-4012
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
)
)
)
)
)
)
)
)
)
No, 01 - ~()/~
C/0~lY~
vs.
CHARLOTTE BOWMAN, d/b/a
CHARZ SALON,
Defendant.
CONFESSION OF JUDGMENT
Pursuant to the authority granted in the Warrant of Attorney contained in the Note, a copy of
which is attached as Exhibit "A" to the Complaint filed in this action, the undersigned attorney
hereby appears for Defendant and confesses judgment in favor of Plaintiff, PNC BANK, NATIONAL
ASSOCIATION, and against Defendant as follows:
Principal Debt
$1,934.56
Interest through 06/20/01
106.37
Late Charges
127.84
Attorney's Commission
216.88
Total
$2,385.65
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By '" ) /\J~I"0^'-.c./,,- ~ u\{'" C>- ./ '"
DonnaM. Donaher, Esquire
Attorney for PNC Bank, National Association
"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
CIVIL DIVISION
Plaintiff,
NO.
vs.
COMPLAINT IN CONFESSION OF
JUDGMENT
CHARLOTTE BOWMAN, d/b/a
CHARZ SALON,
Code:
Defendant.
Counsel of Record for This Party:
Donna M. Donaher, Esquire
Pa.I.D.#53165
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff ,
Defendant.
)
)
)
)
)
)
)
)
)
No.
vs.
CHARLOTTE BOWMAN, d/b/a
CHARZ SALON,
COMPLAINT IN CONFESSION OF JUDGMENT
AND NOW, comes the Plaintiff, PNC BANK, NATIONAL ASSOCIATION, formerly
Pittsburgh National Bank, by and through its counsel, Tucker Arensberg, P.C., and files this
Complaint confessing judgment in its favor, stating as follows:
1. Plaintiff, PNC BANK, NATIONAL ASSOCIATION ("PNCB"), is a national banking
association organized under the laws of the United States and a citizen of Pennsylvania, with its
main office located at Fifth Avenue and Wood Street, Pittsburgh, Pennsylvania.
2. Defendant is Charlotte Bowman, d/b/a Charz Salon whose last known address is 53
Sample Bridge Road, Mechanicsburg, PA 17055.
3. Defendant, on June 17, 1998, executed a Promissory Note ("Note") and thereby
promised prompt and punctual payment of the indebtedness due under the Note. A true and
correct copy of said Note is attached hereto, incorporated herein and labeled Exhibit "A".
4. By the Note, Defendant promised to pay Plaintiff the principal sum of $9,954.31
together with interest thereon in the manner provided by the Note.
5. There has been no assignment of the Note.
6. Judgment has not been entered on the Note in any jurisdiction against the
Defendant.
7. The judgment by confession sought by PNCB in this Complaint is not being entered
against a natural person in connection with a consumer credit transaction.
:
8. By Warrant of Attorney contained in the Note, Defendant authorized entry of
judgment by confession.
9. Pursuant to the Warrant of Attorney executed by Defendant, Defendant waived the
benefit of all laws exempting real or personal property from execution.
10. Pursuant to the Warrant of Attorney contained in the Note, judgment may now be
entered against Defendant as payment was not made when due creating an event of default under
the Note and, accelerating all amounts due. The Warrant of Attorney also allows judgment to be
entered as of any term.
11. Under the Note, the following amounts are now due by Defendant to PNCB:
Principal Debt $1,934.56
Interest through 06/20/01 106.37
Late Charge 127.84
Attorney's Commission 216.88
Total $2,385.65
12. Under the terms of the Note, Defendant is liable to PNCB for attorney's commission
of 10 percent for collection.
- 2 -
WHEREFORE, Plaintiff, PNCB, demands that a judgment be entered against Defendant as
authorized in the Warrant of Attorney contained in the Note, in the sum of $2,385.65 together with
interest and costs of suit.
TUCKER ARENSBERG, P.C.
.......-...,... .
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By '- ../ L/\{Vv'-. C,- '- j'\.-,,,,--C0 '-..>--/
Donna M. Donaher, Esquire
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
Attorneys for Plaintiff
- 3 -
e
PROMISSORY NOTE
e
Borrower: CHARLOTTE BOWMAN (SSN: 152-70-0059)
dba: CHARZ SALON (TIN: )
6483 CARLISLE PIKE
MECHANICSBURG, PA 17055
Lender: PNC BANK, NATIONAL ASSOCIATION
4242 CARLISLE PIKE
CAMP HILL, PA 17001-8874
Principal ~mount: $9,954.31 Interest Rate: 9.500% Date of Note: June 17, 1998
PROMISE TO PAY. CHARLOTTE BOWMAN ("Borrower") promises to pay to PNC BANK, NATIONAL ASSOCIATION ("Lender"), or order, In
lawful money of the United States of America, the principal amount of Nine Thousand Nine Hundred Fifty Four & 31/100 Dollars ($9,954.31),
together with Interest at the rate ot 9.500% per annum on the:unpald principal balance from June 17, 1998, until paid In full.
PAYMENT. Borrower will pay this loan In 36 payments qt'$319.54 each payment. Borrower's tirst payment Is due July 17, 1998, and all
subsequent payments are due on the same day of each mOflth after that. Borrower's tlnal payment will be due on June 17,2001, and will be
tor all principal and all accrued Interest not yet pal~. Payments Include principal and Interest. The annual interest rate for this Note is computed
on a 365'360 basis; that is, by applying the ratio of the annual interest rate over a year of 360 days, multiplied by the outstanding principal balance,
multiplied by the actual number of days the principal balance is outstanding. Borrower will pay Lender at Lender's address shown above or at such
other place as Lender may designate in writing. Unless otherwise agreed or required by applicable law, payments will be applied first to accrued
unpaid interest, then to principal, and any remaining amount to any unpaid collection costs and late charges.
PREPAYMENT. Borrower may pay without penalty all or a portion of the amount owed earlier than it is due. Early payments will not, unless agreed to
by Lender in writing, relieve Borrower of Borrower's obligation to continue to make payments under the payment schedule. Rather, they will reduce the
principal balance due and may result in Borrower making fewer payments.
LATE CHARGE. If a payment is 15 days or more late, Borrower will be charged 5.000% ot the unpaid portion ot the regularly scheduled payment
or $100.00, whichever Is less. -
DEFAULT. Borrower will be in default if any of the following happens: (a) Borrower fails to make any payment when due. (b) Borrowerbreaks any
promise Borrower has made to Lender, or Borrower fails to comply with or to perform when due any other term, obligation, covenant, 'tlr condition
contained in this Note or any agreement related to this Note, or in any other agreement or loan Borrower has with Lender. (c) Borrower defaults under
any loan, extension of credit, security agreement, purchase or sales agreement, or any other agreement, in favor of any other creditor or person that
may materially affect any of Borrower's property or Borrower's ability to repay this Nole or perform Borrower's obligations under this Note or any of the
Related Documents. (d) Any representation or statement made or furnished to Lender by Borrower or on Borrower's behalf Is false or misleading in any
material respect either now or at the time made or furnished. (e) Borrower dies or becomes insolvent, a receiver is appointed for any part of Borrower's
property, Borrower makes an assignment for the benefit of creditors, or any proceeding is commenced either by Borrower or against Borrower under
any bankruptcy or insolvency laws. (f) Any creditor tries to take any of Borrower's property on or in which Lender has a lien or security interest. This
includes a garnishment of any of Borrower's accounts with Lender. (g) Any of the evenls described in this default section occurs with respect to any
guarantor of this Note. (h) A material adverse change occurs in Borrower's financial condition, or Lender believes the prospect of payment or
performance of the Indebtedness is impaired.
LENDER'S RIGHTS. Upon default, Lender may, after giving such notices as required by applicable law, declare the entire unpaid principal balance on
this Note and all accrued unpaid interest immediately due, and then Borrower will pay that amount. Upon default, including failure to pay upon final
maturity, Lender, at its option, may also, if permitted under applicable law, increase the interest rate on this Note 5.000 percentage points. The interest
rate will not exceed the maximum rate permitted by applicable law. Lender may hire or pay someone else to help collect this Note if Borrower does not
pay. Borrower also will pay Lender that amount. This includes, subject to any limits under applicable law, Lender's attorneys' fees and Lender's legal
expenses whether or not there is a lawsuit, including attorneys' fees and legal expenses for bankruptcy proceedings (including efforts to modify or
vacate any automatic stay or injunction), appeals, and any anticipated post-judgment collection services. If not prohibited by applicable law, Borrower
also will pay any court costs, in addition to all other sums provided by law. If judgment is entered in connection with this Note, interest will continue to
accrue on this Note after judgment at the existing interest rate provided for in this Note. This Nole has been delivered to Lender and accepted by
Lender In the Commonwealth ot Pennsylvania. It there Is a lawsuit, Borrower agrees upon Lender's request to submit to the jurisdiction ot the
courts of CUMBERLAND County, the Commonwealth ot Pennsylvania. Lender and Borrower hereby waive the right to any jury trial In any
action, proceeding, or counterclaim brought by either Lender or Borrower against the other. This Note shall be governed by and construed in
accordance with the laws ot the Commonwealth ot Pennsylvania.
RIGHT OF SETOFF. Borrower grants to Lender a contractual security interest in, and hereby assigns, conveys, delivers, pledges, and transfers to
Lender all Borrower's right, title and interest in and to, Borrower's accounts with Lender (whether checking, savings, or some other account), including
without limitation all accounts held jointly with someone else and all accounts Borrower may open in the future, excluding however all IRA and Keogh
accounls, and all trust accounts for which the grant of a security interest would be prohibited by law. Borrower authorizes Lender, to the extent
permil1ed by applicable law, to charge or setoff all sums owing on this Note against any and all such accounts.
FINANCIAL INFORMATION PROVISION. Borrower agrees to deliver any financial and other business information concerning Borrower that Lender
may request from time to time, such as annual and interim financial statements (all of which shall be prepared in accordance with generally accepted
accounting principles) and federal income tax returns.
YEAR 2000 COMPLIANCE. Borrower has reviewed the areas within its business and operations which could be adversely affected by, and has
developed or is developing a program to address on a timely basis the risk that certain computer applications used by Borrower may. be unable to
recognize and perform properly date-sensitive functions involving dates prior to and after December 31, 1999 (the "Year 2000 Problem"). The Year
2000 Probiem will not result, and is not reasonably expected to result, in any material adverse effect on the business, properties, assets, financial
condition, results of operations or prospects of Borrower, or the ability of Borrower to duly and punctually payor perform its obligations hereunder and
under the Related Documents.
6X'l~ If
06-17-1998
Loan No
e
PROMISSORY NOTE
(Continued)
--
Page 2
GENERAL PROVISIONS. Lender may delay or forgo enforcing any of its rights or remedies under this Note without losing them. Borrower and any
other person who signs, guarantees or endorses this Note. to the extent allowed by law, waive presentment, demand for payment, protest and notice of
dishonor. Upon any change in the terms of this Note, and unless otherwise expressly stated in writing, no party who signs this Note, wtlether as maker,
guarantor, accommodation maker or endorser, shall be released from liability. All such parties agree that Lender may renew or extend (repeatedly and
for any length of time) this loan, or release any party or guarantor or collateral; or impair, fail to realize upon or perfect Lender's security interest in the
collateral; and take any other action deemed necessary by Lender without the consent of or notice to anyone. All such partieS also agree that Lender
may modify this loan without the consent of or notice to anyone other than the party with whom the modification is made. If any portion of this Note is
for any reason determined to be unenforceable, it will not affect the enforceability of any other provisions of this Note.
CONFESSION OF JUDGMENT. BORROWER HEREBY IRREVOCABLY AUTHORIZES AND EMPOWERS ANY ATTORNEY OR THE PROTHONOTARY
OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY TIME FOR BORROWER AFTER
A DEFAULT UNDER THIS NOTE, AND WITH OR WITHOUT COMPLAINT FILED, AS OF ANY TERM, CONFESS OR ENTER JUDGMENT AGAINST
BORROWER FOR THE ENTIRE PRINCIPAL BALANCE OF THIS NOTE, ALL ACCRUED INTEREST, LATE CHARGES, AND Am AND ALL AMOUNTS
EXPENDED OR ADVANCED BY LENDER RELATING TO ANY COLLATERAL SECURING THIS NOTE TOGETHER WITH INTEREST ON SUCH
AMOUNTS, TOGETHER WITH COSTS OF SUIT, AND AN ATTORNEY'S COMMISSION OF TEN PERCENT (10%) OF THE UNPAID PRINCIPAL
BALANCE AND ACCRUED INTEREST FOR COLLECTION, BUT IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS ($500) ON WHICH
JUDGMENT OR JUDGMENTS ONE OR MORE EXECUTIONS MAY ISSUE IMMEDIATELY; AND FOR SO DOING, THIS NOTE OR A COPY OF THIS
NOTE VERIFIED BY AFFIDAVIT SHALL BE SUFFLCIENT WARRANT. THE AUTHORITY GRANTED IN THIS NOTE TO CONFESS JUDGMENT
AGAINST BORROWER SHALL NOT BE EXHAUSTED BY ANY EXERCISE OF THAT AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND
AT ALL TIMES UNTIL PAYMENT IN FULL OF ALL AMOUNTS DUE UNDER THIS NOTE. BORROWER HEREBY WAIVES Am RIGrIT BORROWER
MAY HAVE TO NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF JUDGMENT, EXCEPT ANY NOTICE AND'OR
HEARING REQUIRED UNDER APPLICABLE LAW WITH RESPECT TO EXECUTION OF THE JUDGMENT, AND STATES THAT EITHER A
REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THIS CONFESSION OF JUDGMENT PROVISION TO BORROWER'S ATTENTION OR
BORROWER HAS BEEN REPRESENTED BY INDEPENDENT LEGAL COUNSEL.
PRIOR TO SIGNING THIS NOTE, BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE. BORROWER AGREES TO
THE TERMS OF THE NOTE AND ACKNOWLEDGES RECEIPT OF A COMPLETED COpy OF THE NOTE.
THIS NOTE HAS BEEN SIGNED AND SEALED BY THE UNDERSIGNED.
BORROWER:
~................r........N/-;;;?!.........~.....................................................................
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H LOTTE BOWMAN .............. ..
,
Fixed Rate. Installment.
LASER PRO, Reg. U.S. Pat. & T.M. Off., Ver. 3.25 (c) 1998 CFI ProServices, Inc. All rights reserved.IPA-D20 BOWMAN.LN C30.0VL]
VERIFICATION
The undersigned, Thomas Wittman, hereby verifies the statements of fact contained in the
attached Complaint in Confession of Judgment to be true and correct according to his personal
knowledge, information and belief, and further pledges that this verification is made subject to the
penalties of 18 Pa. C.S.A. s4904 relating to unsworn falsification to authorities.
Date:
C,(tOf61
k--.
~
( Thomas Wittman
Assistant V.P. and Recovery Manager
--==--
BF122415.1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff ,
)
)
)
)
)
)
)
)
)
No.
vs.
CHARLOTTE BOWMAN, d/b/a
CHARZ SALON,
Defendant.
CERTIFICATE OF RESIDENCE
I hereby certify that the precise address of Plaintiff is:
Fifth A venue and Wood Street
Pittsburgh, Pennsylvania 15265
and that the last known address of Defendant is:
53 Sample Bridge Road
Mechanicsburg, PA 17055
\ ~\ { ,"'\ { C~~"-\j~
By .~ '-./\{"J\r--{),... ~-...-/ '-........'i"""'-.. . .
Donna M. Donaher, Esquire
Attorney for PNC Bank
National Association
> .
AFFIDAVIT
The undersigned hereby certifies that the underlying transaction referred to in the attached
Complaint for Judgment by Confession, filed pursuant to Pa. R.C.P. Nos. 2950-2956, is not a
consumer credit transaction. To the contrary, the underlying transaction is a commercial
transaction.
~ . ('~""
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Donna M. Donaher, Esquire
Attomey for PNC Bank, National Association
Swom to and subscribed
befo'C}e this oltU- day
of L.~ ,2001.
BF153453 1 Notarial Seal
.Debra~. Paranay, Notary Public
City of Pittsburgh, Allegheny County
My Commission Expires May 9, 2005
Member, PennsytvanlaAssocialionotNofaties
ACT 105 OF 2000 NOTICE
A JUDGMENT HAS BEEN ENTERED AGAINST YOU BY CONFESSION OF JUDGMENT.
PURSUANT TO 42 PA. C.S.A. ~2737.1, IF YOU WERE INCORRECTLY IDENTIFIED AS A DEFENDANT IN
THE COMPLAINT IN CONFESSION OF JUDGMENT, YOU MAY BE ENTIILED TO COSTS AND
REASONABLE ATTORNEY FEES AS DETERMINED BY THE COURT.
YOU MAY TAKE ACTION TO STRIKE THE JUDGMENT BY FOLLOWING THE PROCEDURE IN RULE 2959
WHICH IS AS FOLLOWS:
Pennsvlvania Rule of Civil Procedure 2959 - Strikinl! Off .JudIDnent.
(aXI) 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 rights of notice and hearing was not voluntary, intelligent and
knowing shall be raised only
(i) in support of a further request for a stay of execution where the court has 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 Pennsylvania Rule of Civil Procedure 2958.3 or Rule 2973.3.
(3) If written notice is served upon the petitioner pursuant to Rule 2956.I(c)(2) or Rule 2973.I(c), the petition shall be
filed within thirty 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 a jury trial would
require the issues to be submitted to the jury the court shall open the judgment.
(1) The lien of the judgment or of any levy or attachment shall be preserved while the proceedings to strike off or open
the judgment is pending.
. .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
)
)
)
)
)
)
)
)
)
)
No.
vs.
CHARLOTTE BOWMAN, d/b/a
CHARZ SALON,
Defendant.
TO: Charlotte Bowman d/b/a
Charz Salon
53 Sample Bridge Road
Mechanicsburg, PA 17055
NOTICE OF ENTRY OF JUDGMENT
Please take notice that on....... )l..u ')~' ;;;L L
, 2001, a Judgment by Confession of
Judgment, was entered against you in the court and at docket term and number set forth above.
The amount of the Judgment is $2,385.65, plus costs.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
CIVIL DIVISION
Plaintiff,
NO. 01- .Ifo/~ a-':L'--r~
vs.
CHARLOTTE BOWMAN, d/b/a
CHARZ SALON,
Defendant.
AFFIDAVIT OF NON-MILITARY SERVICE
Filed on behalf of Plaintiff,
PNC Bank, National Association
Counsel of Record for This
Party:
Donna M. Donaher, Esquire
Pa.I.D.#53165
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
1
IN THE COURT OF COMMON PLEAS OF CUMBERLANDOUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
CIVIL DIVISION
Defendant.
)
)
)
)
)
)
)
)
)
)
)
NO.
Plaintiff,
vs.
CHARLOTTE BOWMAN, d/b/a
CHARZ SALON,
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA )
) SS.
COUNTY OF ALLEGHENY )
I, Donna M, Donaher being duly sworn according to law, hereby depose and say that
the Defendant is not a member of the military service of the United States of America to the
best of my knowledge, information and belief.
,-' '-"-.
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Donna M. Donaher
PNC Bank, National Association
Sworn to and su~~cribed
before me thi~--I'fd8y
of June, 2001.
.iC1fJlID~
~ Public (J
BF153461.1
':\
Notarial Seal
,Debra ~, Paranay, Notary Public
CIty of PIttsburgh, Allegheny County
My Commission Expires May 9, 2005
Member, PennsytvanlaAssoclalionof Notaries
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
v.
CHARLOTTE BOWMAN, d/b/a
CHARZ SALON
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
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No. 01-4012 CIVIL TERM
CERTIFICATE OF SERVICE
UNDER RULE 2958.1
Filed on Behalf of Plaintiff,
PNC BANK, NATIONAL ASSOCIATION
Counsel of Record for This Party:
Donna M. Donaher, Esquire
PA 1.0. No, 53165
TUCKER ARENSBERG, P.C.
Firm No. 287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
NO. t) \- '40 \ -J
C' .. \-\ ~ ,\'V,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
)
)
)
)
)
)
)
)
)
No. 01-4012 CIVIL TERM
v.
CHARLOTTE BOWMAN, d/b/a
CHARZ SALON,
Defendant.
CERTIFICATE OF SERVICE UNDER RULE 2958.1
The undersigned hereby certifies that she did serve a Notice Under Rule 2958.1 of
Judgment and Execution thereon, upon the Defendant on July 5, 2001, by certified mail, at the
following address: 53 Sample Bridge Road, Mechanicsburg, PA 17055.
A true and correct copy of the Notice Under 2958.1 and the return receipt is attached
hereto.
TUCKER ARENSBERG, P.C.
By ~ r '^ ~.~.r.\ 0 c,,-..o~\
Donna M. Donaher, Esquire
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
BF154519.1
TUCKER ARENSBERC, PC.
-~~~~ ~
CELEBRA TINe A CENTUR. Y OF SER. VICE
Donna M, Donaher 412-594-5533
ddonaher@tuckerlaw,com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
No. 01-4012 Civil Term
vs.
CHARLOTTE BOWMAN, d/b/a
CHARZ SALON,
Defendant.
Notice Under Rule 2958,1
of Judgment and Execution Thereon
Notice of Defendant's Rights
To: Charlotte Browman
d/b/a Charz Salon
53 Sample Bridge Road
Mechanicsburg, PA 17055
A judgment in the amount of $2,385.65 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.
1500 ONE PPG PLACE PITTSBURGH, PENNSYLVANIA 15222 412-566-1212 FAX 412-594-5619
Pittsburgh Airport Area . Harrisburg
E-mail tapc@tuckerlawcom
www.tuckerlaw.com
,
TUCKER. AR.ENSBER.C. PC.
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CELEBR.\n:-..c.\ ClNTtIR) OF Sm\ ICE
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
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Do~ M. Donaher
1500 One PPG Place
Pittsburgh, PA 15222
(412) 594-5533
BF154199.1
SENDER: COMPLETE THIS SECTION
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
~\\ot.t.e. 6o..unC4\
d{ bl 0.. ~'v"C\\-z... ~
'5 ~ ~p\e.. 6~ Q..d
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2. Article
3~rvice Type
~ertified Mail
o Registered
o Insured Mail
o Express Mail
o Return Receipt for Merchandi
o C.O.D.
4. Restricted Delivery? (Extra Fee)
DYes
15-99-M-17
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