The URL can be used to link to this page

Home My WebLink About06-0820 (J' . WEST PENNSBORO TOWNSHIP MUNICIP AL AUTHORITY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, CIVIL ACTION - LAW JESSE L. SHINDEL and RENNE y, SHINDEL NO, 06- J;L 0 ~ 12M- Defendants 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 Defendants and confess Judgment in favor of the Plaintiff and against the Defendants 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,c. 354 Alexander Spring Road, Suite 1 Carlisle, PAl 7013 Phone: (717) 249-6333 Jr2 WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, CIVIL ACTION - LAW NO. 06- ~ ~ 0 ~ '"'T;.v-- JESSE L. SHINDEL and RENEE y, SHINDEL Defendants COMPLAINT IN CONFESSION OF JUDGMENT FOR MONEY AND NOW, this ~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, Defendants, Jesse L. Shindel and Renee y, Shindel, are adult individuals with a last known address of III E, Main Street, Plainfield, Cumberland County, Pennsylvania, 3, A true and correct copy of the Promissory Note under which Plaintiff is 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 00/1 00 DoIIars ($1,625,00) plus reasonable attorney fees in the amount Four Hundred Eight Seven and 50/100 ($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, Defendants have 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 Defendants 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 Defendants in the sum of Two Thousand One Hundred Twelve and 50/100 ($2,112.50) plus court costs and interest. Respectfully submitted, By: <.. JCP -------- Donald E. LeFever, EsqUire ID #06902 SALZMANN HUGHES, P,C. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 Phone: (7 I 7) 249-6333 Attorney for Plaintiff WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY ~@~w 2150 Newville Road. Carlisle, PA 17013.7746 . Phone: (717) 243.8220 . Fax: (717) 243-1592 January 17,2006 Jesse 1. & Renee Y. Shindel PO Box 80 Plainfield, PA 17081 HE: PROMISSORY NOTE - 111 E. Main Street Dear Mr. & Mrs. Shindel, Your payment of $30.67 on your Promissory Note dated, October 27, 2005, was due January 1.2006. You are now in default of your Promissory Note, with penalty fees added for a total amount due of$70.85. Unless payment is made within 15 days, judgment will be entered against you, and legal action taken, Sincerely, jA-frh . Yo John M. Epley Township Manager cc: Don LeFever, Township Solicitor. Salmann Hughes tile EXHIBIT "An . ,~@~w ." $ 1,625,00 October ~,;},7, 2005 PROMISSORY NOTE FOR VALUE RECEIVED and intending to be legally bound. JESSE L. & RENEE 't', SHIN DEL, adult individuals with their principal address at I I I E, Main Street. Plainfield, Cumberland County, Pennsylvania (hereinafter "Obligors"), promise to pay to WEST PENI'\SBORO TOWNSHIP MUNICIPAL AUTHORITY, a municipal entity, with its office at 2150 Newville Road, Carlisle, Cumberland County, Pennsylvania (hereinafter "Obligee") the sum of One Thousand Six Hundred Twenty~Five and no/! 00 ($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 annum until all outstanding amounts due hereunder have been paid in full, the same to be payable in equal consecutive monthly principal and interest installments of Thirty and 67/]00 ($30,67) Dollars, said paY1nents commencing on December 1, 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 the sewer connection of Obligor's property located at III E, Main Street, Plainfield, Pennsylvania, Obligors 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 due hereunder and then applied second to any outstanding principal payment due hereunder. Upon default hereunder and failure to cure within fifteen (15) days of written notice thereof, Obligors further do hereby authorize and empower any attorney of any court of record of Pennsylvania or elsewhere to appear for them and to enter judgment against them 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 errors, Judgment hereunder may be confessed on executed or photostatic copies of this Note as many times and in as many jurisdictions as is necessary to secure satisfaction of any nnpaid balance or balances, and the judgment or judh'1l1ents confessed shall be without stay of execution, Obligors specifically waive and release any and all relief from any and all appraisement, stay or exemption laws of any state whether cun'ently in force or hereinafter to be passed, WITl~ESS the due execution hereof this n day of October, 2005, WITNESS: " ~"" /V}~. , '" ~c {'U,d{,~ f---i-L"-;fAP----- (; /7 / EAL) ./ ~SE L.HINDf:L /'l11 ~/' .; . ;1 l.LkfpfJki...1.1ild. Cuj<- ___ / ~\ \.U-.. l\ ~\d.J.J - .~~~-~._.-.-._- RE"iEE Y. SHINDEL JSEAI) "Obligors" ADDRESS: I I I E, Main Street, Plainfield, Pemlsylvania 17013 " . (z=; (0) [p 11 DISC1_OSuRE STATEMENT The undersigned, having read this document in its entirety, and fully understanding it. hereby states. admits, acknowledges, and certifies the to 1I0Wll1g: 1. We, as the Obligors, have this day signed a Promissory Note in which we promise to pay to WEST PENNSBORO TOWNSHIP MuNICIPAL AUTHORITY, the sum of One Thousand Six Hundred Twenty-Five and no/l 00 ($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 us without any prior notice to us and without any right of formal pleading, notice, or hearing before the entry of said judgment. 3, Such a judgment entered against us will automatically create a lien on all real estate owned by us at that time, whether we own it now or acquire it later, 4, Such ajudgment entered against us will entitle the person who owns or holds such a judgment to issue execution against our property which can result in the Sheriff physically attaching or taking possession of said property and selling it at a Sheriffs Sale, 5, That we will be compeIIed and required to hire an attorney to file fornlaI documents to open or sHike such a judgment if we have a valid defense to the action taken against us, and without those documents being filed, we will not have a right to a hearing or trial on such judgment matter. 6, That we have an income, which is at least $]0,000.00 per year. ADDRESS: 111 E, Main Street, Plainfield, Pelllisylvania 17013 WITNESS: ,~ ~LO~U'- '---6rf1.U --E'j~ ''7Z''j' , 'i!ii IUj;': ~EAL) A& ' L. SHINDE " , l~''\.tl L( SkD\c& lJSEAL) RENEE Y. SHINDEL "Obligors" DATE: Oetoher ')7, 2005 ~ ~2 :"-.~:l r-;:> /-\ t"':;'l -Ti ~ <.;;--, ~ li- -" -J r<ri ~:n ~, t.:;) f-"" , In;) --- ~ fr \...0 , '-l ~. C'.' \ ..., ~ -..::, \r\ ~ , -- , ~ "--' i ,. " C) \ t' ~ 1/'\ --- , , .t-: ~') ~n CD .< V d 'i-., ~ '" , ~ ~ . SALZMk'lN HUGHES, P.c. BY: Donald E. LeFever, Esquire Attorney 1.0. 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. 06-820 CIVIL TERM JESSE SHINDEL and RENNE Y. SHINDEL Defendants CIVIL ACTION - LAW AND EQUITY PRAECIPE TO WITHDRAW APPEARANCE TO THI; PROTHONOTARY: Dear Prothonotary: Please withdraw our appearance on behalf of the Plaintiff in the above- captioned action, SALZMANN HUGHES, p,c. By: (~ Donald E.Lel1ever, 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, I, Donald L. LeFever, 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 follows: Jesse L. Shindel Renne Y. Shindel 111 E. Main Street Plainfield, P A 17081 SALZMANN HUGHES, P.C. By: ce? Donald E.LeFever, Esquire Attorney lD#: 06902 354 Alexander Spring Road, Ste 1 Carlisle, Pennsylvania 17013 (717) 249-6333 Attomey for Plaintiff " J ." . WEST PENNSBORO TOWNSHIP And WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : NO. 06-820 CIVIL TERM JESSE SHINDEL and RENNE Y. SHINDEL 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 PAUL L. ZEIGLER, P.C. By: Pau L. Ze gler, Esquire Attorn D # 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, Paul L. Zeigler, Esquire, hereby certify that I have this day served the following persons with a copy ofthe foregoing document, by first class, United States Mail, postage pre-paid, addressed as follow: Jesse L. Shindel Renne Y. Shindel I 1 I E. Main Street Plainfield, P A 17081 PAUL L. ZEIGLER, P.C. By: Paul L. . er, Esquire Attomey ID # 09603 300 Bridge Street, Second Floor P.O. Box B New Cumberland, P A 17070 (717) 920-8420 Attomey for Plaintiff Date: April 26, 2006 ,~'-' .\ 1 (." c . WEST PENNSBORO TOWNSHIP And WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : NO. 06-820 CML TERM JESSE SHINDEL and RENEE Y. SHINDEL 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. PAUL L. ZEIGLER, P.C. By: Paul gler, Esquire Attorney ill # 09603 300 Bridge Street, Second Floor P.O. Box B New Cumberland, P A 17070 (717) 920-8420 Attomey for Plaintiff Date: July 19, 2006 . . CERTIFICATE OF SERVICE AND NOW, this 19th Day of July, 2006, 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: Jesse L. Shindel Renee Y. Shindel 111 E. Main Street Plainfield, P A 17081 PAUL L. ZEIGLER, P.C. 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: July 19, 2006 - w (") :=-n .-I :;C-1"\ rn'i~_ '" '! -r". ,!;:- (..;;:'