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Home My WebLink About06-0818 ~ WEST PENNSBORO TOWNSHIP MUNICIP AL AUTHORITY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION - LA W CHRISTOPHER FINKENBINDER Defendant NO. 06- ~/[ ~ .....,..- I-i!~ CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of attorney, a copy of which is attached to the Complaint as Exhibit "A" filed in this action, I appear for the Defendant and confess Judgment in favor of the Plaintiff and against the Defendant as follows: Amount Owed: $1,625.00 Interest: To be determined Court Costs: To be determined Attorney's Fees: 487.50 TOTAL: $2,112,50 plus interest and court costs By: Donald E. LeFever, Esquire ID # 06902 SALZMANN HUGHES, P.e. 354 Alexander Spring Road, Suite I Carlisle, PA 17013 Phone: (717) 249-6333 Jif .. WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CNIL ACTION - LAW CHRISTOPHER FINKENBINDER Defendant NO. 06- r If COMPLAINT IN CONFESSION OF JUDGMENT FOR MONEY AND NOW, this Cf(j:.. day of February, 2006, comes the Plaintiff, West Pennsboro Township Municipal Authority, by and through its attorneys, Salzmann Hughes, P,c., and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, West Pennsboro Township Municipal Authority, is a municipal entity with a principal place of business situate at 2150 Newville Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant, Christopher Finkenbinder, is an adult individual with a last known address of 11 Pine Lane, Carlisle, Cumberland County. Pennsylvania. 3. A true and correct copy of the Promissory Note under which Plaintiffis confessing judgment is attached hereto, incorporated herein and marked as Exhibit "A". 4. The balance due pursuant to the terms and conditions as reflected on the Demand Promissory Note attached hereto as Exhibit "A" is One Thousand Six Hundred Twenty five and 001100 Dollars ($1,625,00) plus reasonable attorney fees in the amount Four Hundred Eight Seven and SOil 00 ($487.50) for a total of Two Thousand One Hundred Twelve and 50/100 ($2,112.50) plus court costs and interest. 5. The instrument and obligation under which judgment is being confessed has not been assigned. 6. Defendant has defaulted on the obligation to Plaintiff by failing to pay pursuant to the terms and conditions of the Promissory Note. 7. Judgment has not been entered against the Defendant in any jurisdiction for any amount under the instrument. 9. Judgment is demanded as authorized by the warrant of attorney contained in the Promissory Note. WHEREFORE, Plaintiff demands the entry of a Judgment against the Defendant in the sum of Two Thousand One Hundred Twelve and 501100 ($2,112.50) plus court costs and interest. Respectful1y submitted, By: Donald E, LeFever, Esquire ID #06902 SALZMANN HUGHES, p,c. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 Phone: (717) 249-6333 Attorney for Plaintiff \crfl ~ ~@~w WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY 2150 NewviJIe Road, Carlisle, PA 17013-7746 . Phone: (717) 243,8220 . Fax: (717) 243,1592 January 17, 2006 Christopher Finkenbinder PO Box 183 Plainfield, PA 17081 RE: PROMISSORY NOTE - II Pine Lane Dear Mr. Finkenbinder, Your payment of$30.67 on your Promissory Note dated, October 31. 2005, was due Januarv 1, 2006. You are now in default of your Promissory Note, with penalty fees added for a total amount due of$70.85, Unless pa}TIJent is made within IS days, judgment will be entered against you, and legal action taken. Sincerely, fL /rh .Yo John M. Epley T o\vnship Manager cc: Don LeFever, Township Solicitor. Salmann Hughes tile EXHIBIT "A" ~(Q)~W S L62S.00 October :, I , 2005 PRO!\IISSORY NOTE FOR VALUE RECEIVED and intending to be legally bound. CHlUSTOPHER FINKENBI-"'DER, an adult individual with his principal address at II Pine Lane. Carlisle. Cumberland County, Pennsylvania (hereinafter "Obligor"), promises to pay to WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY, a municipal entity, with its office at 2150 Newville Road, Carlisle, Cumberland County, Pennsylvania (hcreinafler "Obligee") the sLIm of One Thousand Six Hundred Twenty-Five and no!lOO ($1,625.00) Dollars, lawful money of the United States of America, together with interest to be paid at a rate of five percent (5.0%) per aJIDum until all outstanding amounts due hereunder have been paid in hIll, the same to be payable in equal consecutive monthly principal and interest installments of Thirty and 67/100 ($30.67) Dollars, said paJ~llents commencing on December I, 2005, with a Ten (10) percent penalty applied to payments not received by the tenth of the month, and continuing on a consecutive monthly basis until all amounts due hereunder have been paid in full. This Promissory Note is in consideration of Obligee's willingness to finance t1le sewer connection of Obligor's property located at 108 Greason Road, Carlisle, Pennsylvania. Obligor may prepay in whole or in part any portion of the principal or interest due hereunder without penalty at any time. Any and all payments hereunder shall first be applied to any interest dlle hereunder and then applied second to any outstanding principal payment due hereunder. Upon default hereunder and failure to cure within fifteen (15) days of wrillen notice thereof, Obligor further does hereby a.uthorize and empower any attomey of any court of record of Pennsylvania or elsewhere to appear for him and to enter judgment against him for the then outstanding balance of this Note, with or without declaration, together with costs of suit and reasonable attorney's fees, and with full release of elTors. Judgment hereunder may be confessed on execnted or photostatic copies of this Note as many times and in as many jurisdictions as is necessary to secure satisfaction of any unpaid balance or balances, and the judgment or judgments confessed shall be without stay of execution. Obligor spcciflcally waives and releases any and all relief from any and all appraisement, stay or exemption laws of any state whether cLllTently in force or hereinafter to be passed. WITNESS the due execution hereof this 2.L day of October, 2005. WITNESS: d~LLL(SEAL) CHRISTOPHER FINKENBINDER "772"'FItc 'A-c {U..J: , .; "Obligor" ADDRESS: 11 Pine Lane, Carlisle, Pennsylvania 170] 3 (g~'V DISCLOSURE STATEMENT The undersigned. having read this document in its entirety, and fully understanding it. hereby states, admits, acknowledges, and cer1ities the following: I, 1, as the Obligor. have this day signed a Promissory Note in which 1 promise to pay to WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY, the sum of One Thousand Six Hundred Twenty-Five and no/100 ($1,625,00) Dollars, 2. The said Promissory Note gives the person who holds or owns the note the right to file and enter judgment against me without any prior notice to me and without any right of fonnal pleading, notice, or hearing before the entry of said judgment. 3. Such a judgment entered against me will automatically create a lien on all real estate owned by me at that time, whether lawn it now or acquire it later. 4. Such a judgment entered against me will entitle the person who owns or holds such a judgment to issue execution against my property which can result in the Sheriff physically attaching or taking possession of said property and selling it at a Sheriffs Sale. 5. That I will be compelled and required to hire an attomey to tile fonnal documents to open or strike such a judgment if I have a valid defense to the action taken against me, and without those documents being filed, I will not have a right to a hearing or trial on such judgnlent matter. 6. That] have an income, which is at least S] 0,000,00 per year. ADDRESS: 1] Pine Lane, Carlisle, Pennsylvania 17013 WITNESS: /~ ud /)'1 ~" , " }Js~p~_ [;J(1./ :::-- L--. (SEAL) PHER I~INKENBINDER I!Obligor!! DATE: October 2.L, 2005 r--_'l r, ,-"" ~1' -L. c~:-. t r;;:'" -< I'D -r;. ..,.. -- ~ ("" r'"', \11 r CJ }? I \,.0 ...,~ , \, " l ....::, "- 6il (,) c., , '-' <.f\ - (,) " ;J "-< )-; ..l) U: -I; 0" C) ~ 'I' ~ SALZMANN HUGHES, p,c. BY: Donald E. LeFever, Esquire Altorney I.D, No, 06902 354 Alexander Spring Road Suite 1 Carlisle, PA 17013 (717) 249-6333 Attorney for Plaintiff WEST PENNSBORO TOWNSHIP WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY IN THE COURT OF COMMON PLEAS OF and CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v, NO. 06-818 CIVIL TERM CHRISTOPHER FINKENBINDER Defendants CIVIL ACTION - LAW AND EQUITY PRAECIPE TO WITHDRAW APPEARANCE TO HIE PROTHONOTARY: Dear Prothonotary: Please withdraw our appearance on behalf of the Plaintiff in the above- captioned action, SALZMANN HUGHES, P,C. By: Donald E,LeFever, Esquire Attorney ID#: 06902 354 Alexander Spring Road, Ste I Carlisle, Pennsylvania 17013 (717) 249-6333 Attorney for Plaintiff Date: April 19, 2006 . ., , CERTIFICATE OF SERVICE AND NOW, this 19th Day of April, 2006,!, Donald L. LeFever, Esquire, hereby certify that! have this day served the following persons with a copy of the foregoing document, by first class, United States Mail, postage pre-paid, addressed as follows: Christopher Finkenbinder 11 Pine Lane Plainfield, PA 17081 SALZMANN HUGHES, P,C, By: ucD, Donald E.LeFever, Esquire Attorney ID#: 06902 354 Alexander Spring Road, Ste I Carlisle, Pennsylvania 17013 (717) 249-6333 Attorney for Plaintiff ., " , WEST PENNSBORO TOWNSHIP And WEST PENNSBORO TOWNSHIP MUNICIP AL AUTHORITY Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : NO. 06-818 CIVIL TERM CHRISTOPHER FINKENBINDER Defendants : CIVIL ACTION - LAW AND EQUITY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Dear Prothonotary: action. Please enter our appearance on behalf of the Plaintiff in the above-captioned By: PaulL.' er, Esquire Attorney 10 # 09603 300 Bridge Street, Second Floor P.O. Box B New Cumberland, P A 17070 (717) 920-8420 Attorney for Plaintiff Date: April 26, 2006 . CERTIFICATE OF SERVICE AND NOW, this 26th Day of April, 2006, I, PaulL. Zeigler, Esquire, hereby certify that I have this day served the following persons with a copy of the foregoing document, by first class, United States Mail, postage pre-paid, addressed as follow: Christopher Finkenbinder P.O. Box 183 Carlisle, P A 17081 PAUL 1. ZEIGLER, P.C. By: PaulL. ZIgler, Esquire Attorney ID # 09603 300 Bridge Street, Second Floor P.O. Box B New Cumberland, P A 17070 (717) 920-8420 Attorney for Plaintiff Date: April 26, 2006 ., WEST PENNSBORO TOWNSHIP And WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : NO. 06-818 CIVIL TERM CHRISTOPHER FINKENBINDER Defendants : CIVIL ACTION - LAW AND EQUITY PRAECIPE TO SATISFY AND DISCONTINUE TO THE PROTHONOTARY: Dear Prothonotary: Please mark the above-styled action satisfied and discontinued. By: Paul L. . er, Esquire Attorney ID # 09603 300 Bridge Street, Second Floor P.O. BoxB New Cumberland, P A 17070 (717) 920-8420 Attorney for Plaintiff Date: April 10, 2007 CERTIFICATE OF SERVICE AND NOW, this 10th Day of April, 2007, I, Paul L. Zeigler, Esquire, hereby certify that I have this day served the following persons with a copy of the foregoing document, by first class, United States Mail, postage pre-paid, addressed as follow: Christopher Finkenbinder P.O. Box 183 Plainfield, P A 17081 By: Paul L. Ze ler, Esquire Attorney ID # 09603 300 Bridge Street, Second Floor P.O. Box B New Cumberland, PA 17070 (717) 920-8420 Attorney for Plaintiff Date: April 10, 2007 () s; ~,~ l"'--' c;;,,-:> c.""~ --' Y" -;'") ..-" ....'""...... -0 > o ~\ ~~, cr1r: 8 ;~% . ) ::::.\ Jfj ::.:. <.Jl r-.)