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HomeMy WebLinkAbout05-5898 KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05: - ~f"1P Cl-U~L. ~ 8<-""\. MANUFACTURERS AND TRADERS TRUST COMPANY v. LORI EN A. PERKINS and KIRK A. PERKINS, Individually and d/b/a KAPLAS SYSTEMS CONFESSION OF JUDGMENT Defendants NOTICE OF DEFENDANTS' RIGHTS A judgment in the amount of $51 ,691.44 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 AND CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET Carlisle, PA 17013 Telephone (800) 990-9108 KEEF~EN & RAHAL, LLP By. ~ Eugene E. Pepinsky, Jr. Attorney I.D. #23702 210 Walnut Street PO, Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Manufacturers and Traders Trust Company KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX ~1963 HARRISBURG. PA 17108.1963 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW o S" _ roof> NO. ..::)(} { (!. L'0 L '-y 8?..~ MANUFACTURERS AND TRADERS TRUST COMPANY v. LORIEN A. PERKINS and KIRK A. PERKINS, Individually and d/b/a KAPLAS SYSTEMS CONFESSION OF JUDGMENT Defendants CONFESSION OF JUDGMENT By virtue of the authority conferred by the Note, and a copy of which is attached to the Complaint filed in this action, I appear for the Defendants and confess judgment in favor of the Plaintiff and against the Defendants for the sum of $51 ,691.44, and costs of suit. E"~kY' J, Attorney for Defendants by virtue of the authorization contained in the Note KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 MANUFACTURERS AND TRADERS TRUST COMPANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW NO. OS" - Sny Clu'll- VL~ v. LORIEN A PERKINS and KIRK A PERKINS, Individually and d/b/a KAPLAS SYSTEMS CONFESSION OF JUDGMENT Defendants COMPLAINT 1. Plaintiff Manufacturers and Traders Trust Company is a New York banking corporation, with an office at 213 Market Street, Harrisburg, Pennsylvania 17105. 2. Defendant Lorien A Perkins an adult individual, whose last known address is 5977 Eberly Drive, Mechanicsburg, Pennsylvania 17055. 3. Defendant Kirk A Perkins an adult individual, whose last known address is 6030 Creekview Road, Mechanicsburg, Pennsylvania 17050. 4. On or about July 3,2000, Defendants, for good and valuable consideration, executed and delivered a Promissory Note (the "Note") to plaintiff's predecessor. A true and correct copy of said Note is are attached hereto, made a part hereof and marked Exhibit "A". 5 The Note referred to in Paragraph 3 above has not been assigned by Plaintiff to any person or organization. 6. Judgment has not been entered on the Note referred to in Paragraph 3 above in any jurisdiction. 7. The Note provides that Plaintiff may confess judgment against Defendants for the full principal balance and interest, together with court costs and with ten percent (10%) for attorneys' fees. 8. The Defendants' obligations are in default, among other things, by reason of the failure to make the payment(s) due to Plaintiff. KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 9. The amount due on the Note as of November 10, 2005, is $46,999.30, of which $46,920.64 is principal and $78.74 is interest. Ten percent (1 0%) of said principal sum is $4,692.06 10. Plaintiff has been advised and, therefore, avers that Defendants executed the Note referred to in Paragraph 3 above for business purposes. 11. Plaintiff believes and, therefore, avers that Defendants' annual income exceeds $10,00000. 12. This confession of judgment is not being filed against a natural person(s) in regards to a consumer credit transaction. WHEREFORE, Plaintiff demands judgment against Defendants in the sum of $51 ,691.44, together with interest as may hereafter accrue and costs of suit. Date: November 10,2005 KEEFER WOOD ALLEN & RAHAL, LLP B~0 Eugene . eplnsky, Jr. Attorney ID #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG. PA 17108-1963 VERIFICATION The undersigned Walter Leader, hereby verifies and states that: 1 He is Banking Officer of Manufacturers and Traders Trust Company: 2. He is authorized to make this Verification of behalf of Plaintiff ; 3. The facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief; and 4. He is aware that false statements herein are made subject to the penalties of 18 Pa.C.S.S1904. relating to unsworn falsification to authorities. {f!L ~der Dated: November~. 2005 AUG. 8"2005 12 09P\~ NO. 822 p 2 .- PROMISSORY NOTE Borrower: Lorlen A.. Perkins and Kirk A. perkins, indlvidu~lly and .s partners, db. Kaplas Systems 50n Eberly Drive Mechanicsburg, PA 17055 OBLGR!: ._._._.......:~.1.5.LS:t; DOC TYPE. . . .. . ~-- 3 O/J. OBLGT ._._._._.~._._._.1k. COMMEJI."1" $ .~ IFII'D ~ DATE -..-!_,~ Principal Amount: $50,000.00 Initial Rate: 10.500% Date of Note: February 3, 2000 PROMISE: TO PAY. Lorlen A. perkins and Kirk A. Perkins, individually and as partners, db. Kaplas Systems ("Borrower") promises to pay 10 KEYSTONE: FINANCIAL BANK, N.A. ("Lender'), or order, In lawfUl money 01 the United SIales 01 America, the prinCipal amounl 01 Fifty Tllousand & ooJ1oo Dollar$ ($50,000.00) or so much as may De outstanding, together with interest on the unpaid outstanding principal balance of each advance. Interest shall be c.lculated Irom the date Of each advance until repaymenl of each advance. PAYMENT, Borrower will pay Ihis loan on demand, or If no demand is made, In one paymenl of all oulstandlng principal plUS all a..",ad unpaid Inlerest On February 3,2005. In add~ion, Borrower will pay regul.r monthly payments of accrued unpaid inlerest beginning March 3, 2000, and all subsequenllnteresl paymenls are due on Ihe same day 01 each month aIIer thaI. Interest on this Note is computed on a 365/365 simple interest basis; that is, by applylng the ratio of the annual interest rate over the numb~r of days in a year. multiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance is olitstanding. Borrower will pay Lender at Lender's addril~ shown above. or at such other place as Lender may designate In wriling. Unless otherwise agreed or requifed 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. VARIABLE INTE:RE:ST RATE. The interest rate on this Note is subject to change from time to time based on changes in an independent index which is the Prime Rata as published eaoh business day in the Wall street Journal. When a range Of rates has been published, the lower of the ra.tes wiU be used (the 1'I!'1dex'~. The lndex is not necessarily thQ lowest rate oharged by lender on its loans. If the Index becomes unavailable during the term of this loan, Lender may designate a substitute index after notIce to Borrower. Lender will tell Borrower the cUfl'8nt Index rate upon Borrower's request. SOn'ower understands that Lender may make losl"ls based on othe.r rates as well. The interest ra1e change will not OCCUr more often than each Calendar Quarter. The Index currently is ',501l% per annum. Tne inlereSl rale 10 be applied to Ihe unpald principal balance Of lhis Nole Will be a1 a rate Of 2.000 percentage points over the Index, reSUlting in an initial rate of 1(J.500% per annum. NOTICE: Under no circumstances will the interest rate on this Note be more than the maximum rate allowed by applicable law. PREPAYMENT. Borrower may pay without penalty all Or a portion of the amount owed earlier than It Is due. EArly payments wm 1'\ot, unless agreed to by Lende( in writing, relieve Borrower of Borrower's obligation to continue to make payments of accruad unpaid interest. Rather, they wJIIl'educe the principal balance due. LATE CHARGE. If a payment is 10 days or more lale, Borrower will be Charged 5.000% Of Ihe regutarly scheduled payment. DEFAULT. Borrower will be in detault it any of the following happe~s: (a) Borrower lails to make any payment when due. (b) Borrower breaks any promise Son-oWer has made to Landarl or Borrower fails to comply with or to perform when due any other term, obligation, covenant, or condition contained in this Note or any agreement relateCl to this Note, or tn any other agreement or loan Borrower has with Lender. (c) Borrower defaults under any loan, BXfension of credit, secuflty agreeme"t, purChase Or sales agreement, or any oth9r a,grs9ment, in favor of any other qredltor or person that may materially affect any of Borrower's property or Sorrowecs abilily 10 repay this Note cr perform Borrower's obligations under this Note or any of the Relaled Documents. (d) Any ,ep'''''enla~on or stalemem made or lurnisheo to Lender by Borrow", or on 80rrowe(s behelf Is false Of miSleading in any material respect either now or at th8 time made or turnilShed. (e) Any partner dies or any of the partners or Borrower becomes insolvent, a receiver is appointed for aflY part of Borrower's property, Borrower makes an assignment for the benefit of creditort, or any proceeding \5 commenced ei~her by Borrower or against Borrower under any bankruptcy o( insolvency laws. (f) Any creditor tries to take a.ny of Borrowers property on or in which Lsndar has a lien or security interest This includes a garnishment of any of 8orrower's accounts with Lender. (g) Any of tho events described in this default section occurs wrth respect to any gene.ral partner of Borrowar or any guarantor of this Note. (h) A material adverse Change occurs in Sorrower's finanCial Cionditionr or Lender beliavBs tha prospect of payment or performance of the Indebtedness rs impaired. Q) Lender in good faith deems itself insecure_ LENDER'S RIGHlS. 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 unp.a.id interest Immediately due, and then Borrower will pay that amount. Lender ma.y hire or pa.y someone else to help collect this Note it Borrower does not pay. Borrower also will pay Lgnde[ that amount. This includas, subject to any limits undar applicable law, Lender's attorneys' feBS and Lender's legal expenses whether or not there is a lawsut~. lnC\\.ldlng attorneys' fees and legal expenses 10r bankruptcy proc8Gdings (including eHorts to modify or vacate any automatic stay or InJuncllcn), appeals. .nd any anticipated post-judgment ccilectlon 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 interest rate applicable to this Note at the time judgment is entered. Ih'S Note has been delivered to Lender' ar1d accepted by Lender' in the Commonwealth of PennsYlvania. If there is a lawsuit, Borrower agrees upon Lender'S request to submit to the jUl'iSdicticn of the courts of Dauphin county, the CommonWealth of Pennsylvania. ThiS Note shall be governed by and construed in accQr'dance with the laws 01 the Commonwealth of Pennsylvl:mia. RIGHT OF SETOFF. Borrower grnnts 10 lender a contractual seourlty Interesl In. and hereby assigns, conveys, dellve.., pledges. and tra~sfe.. to Lender ail Borrower's right. title and interest in and to, BCffowef's acccunts with Lender (whether checking, savings, or scme other account). including without limitation arl accounts hsld jointly with someone slse and all accounts. Borrowar may open in the futural excluding however all IRA and KeOgh accounts! and all trust accounts for which the grant of a security interest would be prohibited by law. Borrower authorizes Le/'lder, to the extent permItted by applicable laW, to charge or setoff all sums OWing on this Nots against any and all such accounts, and, at Lender's option, to administratively freeze all such accounts to allow Lender to proted Lend€r's charge and setoff rights provided on this paragraph. LINE OF CREDIT. This Note evidences a revolving line of credit. Advances under this Note may be requested orally by Borrower or by an authoriz.ed perSon. All oral requests shall be confirmed in writing on the day or the request. All communications, instructions! or directions by telephone or otherwise to Lander are to tJa directed to Lender's office shown above. The following par"t}' or parties are authorizsd to request advances undsr the line of credit untl\ Lender recei\l~rs from Borrower a1 LBndiiirs address shown abov9 writhm nonce ot revocation of their authority: Lorien A. Perkins and Kirk A. Perkins. Borrower a.grees to be liable for all sums either: (s) advanced in accordance with the instructions of an authorized person or (b) credited to any cl Sorrowe,', accounts with Lender. The unpaid principal balance owing on this Note at any lime may be evioenced by endorsemenls on this Note or by Lender'!; Internal records, including daily computer print-outs. Lender will have no obligation to advance funds uncter this Note. if: (a) BorroWer or any guarantor is in default under th~ tsrms of this Note or any agreement that Borrower or any guarantor has wIth Lender, including any agreement made in connection with the Signing of 1hh; Note; (b) Borrower or any guarMtor ceases doing business or is insolvent; (c) any guaJ"Sntor seeks claims or ottJerwise attempts to limitr modify or revoke SUCh guarantor's guarantee of this Note or any othsr loan with Lenderj (d) Borrower has app\i~d fUnd5 provided ptlr5uant to this Nate ior purposes olher than those aUlhorizao by Lender; or (e) Lender in good faith deems itself insecure AUG. 8'2005 12: 10PM NO.8 2 2 P 3 02-&3~2SOO . PROMISSORY NOTE (Continued) Page 2 under this Note or any other agreement tletvJeen Lender and Borrower, GENERAl PROVISIONS. ThiS Note is payable on d~mand. The inclusion of speoifio defaull provisions or rights of lender shall not preclude Lender's fight to declare pa.yment of this Note on its t:lernand. Lender ma.y d8lay or forgo enforcing any of its rights or remedfes under this Note without losIng them. Borrower and any other person who signs, guarantees or el'ldofSes 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 s1gns this Note, whether as maker, guarantor, accommodation ma,k!:if or endorser, shall be released from liabinty. All such parties agree fhat Lender may reneW or extend (repeatedly and for any length of time) this loan, or release any party, partnerl or guarantor or coDateralj or impair, fail to realize upon or perfect Lender's security intl:lrest in the. collateral; and take any otl1er aotio" deemed necessary by Lender wltl10ut the cot"t!lent of or notice to anyone. All such parties also agree that Lender may modify thJs loan without the consent of or nofice to anyone other than the party with whom the modification is made. If any portion of tliis Note is fOr any reason determined to be unenforceable, it wi!! not affect the enforceability of any other provisions Of this Note. CONFESSION OF JUDGMENT. BORROWER HEREBY IRREVOCABLY AlfTHORIZES AND EMPOWERS A~ ATTORNEY OR THE PROTHONOTARY OR CLERK OF ANY COURT IN THE COMMONWEAL TIi OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY TIME FOR BORROWER AFTER A DEFAULT UNDER THIS NOTE, AND WITH OR WITHOlfT 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 ANY 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 ATIORNEY'S COMMISSION OF TEN PERCENT (10%) OF THE UNPAID PRINCIPAL BALANCE AND ACCRUED INTEREST FOR COLLECTION, BUr IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS ($500) ON WHICH JUDGMENT OR JUDGMENTS ONE OR MORE EXEClJTlONS MAY ISSUE IMMEDIATELY; AND FOR SO DOING, TIiIS NOTE OR A COPY OF THIS NOTE VERIFIED BY AFFIDAVIT SHALL BE SUFFICIENT WARRANT, THE AlJTHORJ"iY GRANTED IN THIS NOTE TO CONFESS JUDGMENT AGAINST BORROWER SHALL NOT BE EXHAUSTED BY ANY EXERCISE OF THAT AlJTHORI"iY, 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 ANY RIGHT 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 EXEClJTlON 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 THE LIEN ARISING FROM A~ JUDGMENT CONFESSED OR ENTERED PURSUANT TO THE FOREGOING AlJTHORITY SHALL NOT EXTEND TO Am OF BORROWER'S RESIDENTIAL REAL PROPERTY AS THAT TERM IS DEFINED IN THE PENNSYLVANIA ACT OF JANUARY 30, 1974 (PA, LAWS 13, NO.6), REFERRED TO AS THE LOAN INTEREST AND PROTECTION LAW, AS AMENDED, AND THE HOLDER OF ANY JUDI3MENT CONFESSED OR ENTERED PURSUANT TO THE FORGOING ALlTHORITY SHALL NOT, IN ENFORCEMENT OF ANY SUCH JUDGMENT, EXECUTE, LEW OR OTHERWISE PROCEED AGAINST ANY SUCH RESIDENTIAL REAL PROPERTY; PROVIDED, HOWEVER, THAT THE LIEN OF SUCH JUDGMENT SHALL EXTEND TO SUCH RESIDENTIAL REAL PROPERTY AND THAT THE HOLDER THEREOF SHALL BE PERMITTED TO EXECUTE, LEW OR PROCEED AGAINST SUCH RESIDENTIAL REAL PROPERTY FROM AND AFTER THE ENTRY OF A JUDGMENT AS CONTEMPLATED BY SECTION 407 OF SUCH LOAN INTEREST AND PROTECTION LAW AND RULES 2981 TO 29116 OF THE PENNSYLVANIA RULES OF CIVIL PROCEDURE, OR SUCCESSOR OR SIMILAR STATUTES AND RULES. NO LIMITATION OF LIEN OR ANY EXEClfTION, LEW OR OTHER ENFORCEMENT CONTNNED IN THE IMMeDIATELY PRECEDING SENTENCE SHALL APPLY WITH RESPECT TO ANY JUDGMENT OBTAINED OTHER THAN BY TIiE FOREGOING AlfTHORITY TO CONFESS OR ENTER JUDGMENT. PRIOR TO SIGNING THIS NOTE, BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE, INCLUDING THE VARIABLE INTEREST RATE PRDVISIONS, BORROWER AGREE;S TO THE TERMS OF THE NOTE; AND ACKNOWLEDGES RECEIPT OF A COMPLETED COpy OF THE NOTE. THIS NOTE HAS IlEiON SIGNiOD AND SEALED BY THiO UNDERSIGNED. ,.. . ;C^);)=,l>.~Ml:IM,_(N('\IIX ":'~';~,;'=;c;~, .....) . \~:tfif~',::;;;;,':~~u"".u.t\::., 'A\~'~=~~'!~.~)f:':'\"''''._':) ra ortner . . V;ViatJle Rate. Line Of creQ'i1. LAseR PRO, Reg. U.S, P~1..& T.M. Off., Ver. :H.7.!. (~) :2000 CF'l F'roSer.'lces, Inc. .All r ghts rllSer.llld. (F'A D20 E:l.27 F3.27 Pa.27 P5F\KIN$.l.N C2.0Vl.] t )::J ~ ~ r::. ........ #:- II --G ~ r' ....:z f ~ ~ r ~ ~ --:::t D ----- Il.J' ; (~) b . -_.- (~i ( --I- -'.:, W -+- -.( KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 MANUFACTURERS AND TRADERS TRUST COMPANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW v. NO, oS- - SpqF r!.t ~~L~VL~ LORIEN A. PERKINS and KIRK A. PERKINS, Individually and d/b/a KAPLAS SYSTEMS CONFESSION OF JUDGMENT Defendants NOTICE To: LORIEN A. PERKINS and KIRK A. PERKINS, Defendants You are hereby notified that on November ILl , 2005, judgment by confession was entered against you in the sum of $51 ,691.44 in the ~ captioned case. Dated: November~, 2005 ~ ,-- 'Proth YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET Carlisle, PA 17013 Telephone: (800) 990-9108 I hereby certify that the following is the address of the defendant(s) stated in the certificate of residence, Lorien A. Perkins 5977 Eberly Drive Mechanicsburg, PA 17055 Kirk A. Perkins 6030 Creekview Road Mechanicsburg, PA 17050 Atto~pa KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MANUFACTURERS AND TRADERS TRUST COMPANY v, NO. of; - SJXff (}1~lL'-rVL~ LORIEN A. PERKINS and KIRK A. PERKINS, Individually and d/b/a KAPLAS SYSTEMS CONFESSION OF JUDGMENT Defendants NOTICE LORIEN A. PERKINS and KIRK A. PERKINS, Defendido Usted esta siendo notificando que el_ de Novemberdel2005, se anoto en contra suya un fallo por confesion en la suma de $51,694.44 en el caso men cion ado en el epigrafe. FECHA November ~,2005 Prothonotary USTED DEBE LLEVAR IMMEDIATAMENTE ESTE DOCUMENTO A SU ABOGADO. Sl USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE A UNO, LLAME 0 VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET Carlisle, PA 17013 Telephone (800) 990-9108 Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: Lorien A. Perkins 5977 Eberly Drive Mechanicsburg, PA 17055 Kirk A. Perkins 6030 Creekview Road Mechanicsburg, PA 17050 ~)d Attorney f Plaintiff(s)