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HomeMy WebLinkAbout06-1856 KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG. PA 17108,1963 MANUFACTURERS AND TRADERS TRUST COMPANY Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. olz. -IP $b (!lu;L~'C/LhJ. CONFESSION OF JUDGMENT v. L&L PARTNERS, L TO. Defendant CONFESSION OF JUDGMENT By virtue of the authority conferred by the Suretyship, a copy of which is attached to the Complaint filed in this action, I appear for the Defendant and confess judgment in favor of the Plain- tiff and against the Defendant for the sum of $159,631.70, and costs of suit. EU~P:SkY' Jr. Attorney for Defendant by virtue of the authorization contained in the Suretyship 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. L&L PARTNERS, L TO. CONFESSION OF JUDGMENT Defendant NOTICE OF DEFENDANTS' RIGHTS A judgment in the amount of $159,631.70 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 KEEFER WOOD ALLEN & RAHAL, LLP ~~ By: Eugene E. Pepinsky, Jr. Attorney 1.0. #23702 210 Walnut Street P.O. 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 11963 HARRISBURG, PA 17108,1963 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01.... - ! g>')~, G'U~tT~ CONFESSION OF JUDGMENT MANUFACTURERS AND TRADERS TRUST COMPANY v. L&L PARTNERS, L TO Defendant COMPLAINT 1. Plaintiff Manufacturers and Traders Trust Company is a New York banking corporation, successor to Allfirst Bank, with an office at213 Market Street, Harrisburg, Pennsylvania 17105 2. Defendant L&L Partners. Ltd. is a partnership, whose last known address is 100 Market Street, Lemoyne, Pennsylvania 17043. 3. On or about November 21, 1997, Defendant, L&L Partners, Ltd., for good and valuable consideration, executed and delivered a Suretyship Agreement (the"Suretyship") to Plaintiffs predecessor. A true and correct copy of said Suretyship is attached hereto, made a part hereof and marked Exhibit "A", 4. The Suretyship referred to in Paragraph 3 above has not been assigned by Plaintiff to any person or organization. 5. Judgment has not been entered on the Suretyship referred to in Paragraph 3 above in any jurisdiction. 6. The Suretyship provides that Plaintiff may confess judgment against Defendant for the total liability of Defendant as set forth therein, together with interest thereon and court costs and with fifteen percent (15%) for collection fees. KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG. PA 17108,1963 7. The amount due on the Suretyship as of March 29. 2006, is $138,810.28. Fifteen percent (15%) of said sum is $20,821.42. 8. 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 Defendant in the sum of $159,631.70, together with interest as may hereafter accrue and costs of suit. KEEFER WOOD ALLEN & RAHAL, LLP Date: March 29, 2006 By: ~~ Eugene E. Pepinsky, Jr. Attorney I.D. #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 Kenneth L. Milliken, hereby verifies and states that: 1. He is Vice President of Manufacturers and Traders Trust Company, Plaintiff herein; 2. He is authorized to make this Verification on its behalf; 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. S 4904, relating to unsworn falsification to authorities. ~~~./;?/~ Kenneth L. Milliken Dated: March 2-7 ,2006 . MAR-29-06 WED 01:46 PM MTB SPECIAL ASSETS L-e.~+-'"r.r'. V'J' Sr..... 1.-1111""1 , FAX NO, 717 255 2370 ( /-<- SURETYSHip AGREEMENl\ '-5., I.... '-1. r J" " ~ ., t'J '- -, ., 'J' - ~vr.) P. 06 'I (AHa DAUPHIN DEPOSIT BANK AND TRUST COMPANY BANK OF PENNSYLVANIA . FARMERS BANK . VALLEYBANI< 01:'':' (; () (Bank of Pennsylvania. Farmers Bcmk and Val/eybankare divisions of Dauphin Deposit Bank and Trust Company) Oato November 2 I 1997 I For value received, the Undersigned, jointly and severally, ryerebY uncon~itionally agree t? make prompt paYn:'e~t of all obligation~. indebtedness i!l1d liabilities due Dauphin Deposit Bank and Trust Company, hereinafter called Bank,1I of any kind. whether now eXisting or hereafter arising. due or which may b>>~~ due whj!thar ~ln'...JlcceletatLon Qr otlwrwise. "absolute or contingent. joint or several. direct or indirect. secured or unsecured by LlSln-ER IV. liINAl'llU and LILLIAN R. GINANNI hereinafter called "Borrower," all such obligatIons beIng hereinafter further descnbed and collectively called the "UablhtI8S.Q and the Undarsigno'd agroc(s} 10 pay all expenses (including attom~s' fees and legal expenses. whether or not litigation is c';lmmenc~d) ps!d or incurr~d by tha Bank in e~de.fl.voring to collect the Liabilities, or any part thereof. whether or not bankruptcy has been declared. and In enfo!clng this Suretyship Agreement. Tho liability of the Undersigned hereunder is a primary and direct obligation without regard to an,Y other obligor ~r security ,!r collateral held by the ~an.k: , The Undersigned hereby waive all notices of any character whatsoever With respect to thiS Suretyship Agreement and the LiabIlities of the Borrower for which the Suretyship Agreement has been executed. including but not limited to notice of the acceptance hereof and reliance hareon and notice tlf default by the Borrower. The Undersigned hereby give consent to 1he Bank to the taking of. or failure to take. from time to time. without notice to tho UnderSIgned. any action of any nature whatsoever with respect to the liabilities of the Borrower. with respect to any rights against any person or parsons, including the Borrower and any of the Undersigned, in any property, including. but not limited to, any postponements, compromises, indulgences. w.;llvers. extensions. exchanges, releases. and satisfactions. The Undersigned shall remain fully liable on this Suretyship Agreement. notwithstanding any of the foregoing. This Suretyship Agreement shall in all respects be a continuing. absolute and unconditional one. and shall remain in full forcQ and effect (notwithstanding, without limitation. the death, incompetency or dissolution of any of the Undersigned or that at any time. Of from timo to tlma, till Uabilitles may have been paid in full), This Suretyship Agreement is subject to discontinuance as to any of the Undersigned only upon actual receipt by the Bank of written notice from such Undersigned, or any person duly authorized and acting on behalf of such Undersigned. of the discontinuance horaof as to such Undersigned; provided, however, that no such notice of discontinuance shall affect or impair any of the agreements and obligations of such Undersigned hereunder vvith respect to (a) any and all Uabilities existing prior to the time of actual receipt of such notice by the Bank, (bl any and nil Uabilities created or acquired thereafter pursuant to any previous binding commitments made by the Bank. (c) any and all extensions or ranowals of any of the foregoing. (d) any and all interest on any of the foregoing, and (e) any and all expenses paid or incurred by the Bank in endeavoring to collect any of the foregoing and in enforcing this Suretyship Agreement against such UnderSigned. All obligations of the Undersigned under this Suretyship Agreement shall. notwithstanding any such notice of discontinuance. ramain fully in effect until all Liabilities not subject to an effective notice of discontinuance (including any extensions or renewals of any thereof) and all such interes1 and expenses shall have been paid in full. Any notice of discontinuanco by or on behalf of anyone of the Undersigned shall not affect or impair the obligations hereunder of any other of the Undersigned. At the option of Bank. aU liabilities of Borrower shall become immediately due and payable by the Undersigned. without demand or notice, In lha event any of the following shall occur: (a) Borrower shall fail to make any payment or meet any other liability when due; (b) Borrower or the Undersigned shall fail to observe or perform any obligation. term, condition or provision of Borrower under any document evidencing or securing tho Liabilities, th1s Surelyship Agreement or any other agreement, document, certificate, instrument of security, suretyship or guaranty given by Borrower to B.:lnk: (c) Any representation. warranty or certificate made or furnished by Borrower to Bank. in connection with the liabilities or any other agreement, docllmenl, certificate, instrument of security, suretyship or guaranty given by Borrower to Bank or in any certificate, financial statement or separa10 assignment made thereunder shall be materially false: (d) Borrower or any of the Undersigned shall make an assignment for the benefit of creditors; (e) Proceedings in bankruptcy or for reorganization of Borrower or any 01 the Undersigned or for the readjustment of any of their debts under the Bankruptcy Act, as amended. or in any part thereof, or under any other act or law, whether state or federal. for the relief of debtors now or hereafter existing, shall be commenced by or against Borrower or the Undersigned; (f) A receiver or trustee shall be appointed for Borrower or any of the Undersigned or for any substantial part of their assets; or any proceedings are instituted for the dissolution. or the full or partial liquidation. of Borrowor or any of the Undersigned; (g) Material adverse changes in the financial condition of the Borrower or any of the Undersigned; (h) A death of Borrower or any of tho Undersigned or. if Borrower or the Undersigned is a partnership. the death of any general partner; or (il Borrower or any of the Undersigned coases doing business as a going concern, As security for the Liabilities hereunder. the Undersigned hereby grants Bank a security interest In the following: . Improved real estate in Cumberland County and A11egh~ny County in accordance with Commercial Mortgages and Security Agreements of even date. Toge,ther with a right.. without demand or notice of any kind. at any time and from time to time when any amount shall be due and payablo by the Undersigned hereunder and In such order of application as the Bank may elect to set..off against all monies, deposits or other proporty of any kind, without limitation. owned by the Undersigned or in which the Undersigned has a joint or contingent interest and which are in possession of Bank for any reason whatsoever. The Undersigned further agree that, if a1 any time. any part of any payment theretofore applied by the Bank to any of the Liabilities Is or must be returned by the Sank for any reason whatooever (inCluding. without limitation, the insolvency. bankruptcy or reorganization of tha Borrower). such Uabilities shall, for the purposes of this Suretyship Agreement. to the extent that such payment is or must be rescinded or returned. be deemod to have continued in existenca. notwithstanding suc" application by the Bank. and this Suretyship Agreement shall continua to be effective or be reinstated, as the case may be as to such UabHities. all as though $uch application by the Bank had not been made. In such an event the Undersigned horoby waives any right of contribution. subrogation or Indemnlfica1ion against the Borrower, for a period of tvvelve (12) months subsequent to the last paymont melds or due to be made from Borrower to Bank. The Bank may. from time to 1ime, whether before or after any discontinuance of this Suretyship Agreement. at its sole discretion and without notice to the Undersigned (or any of them). take any or all of the following actions: (a) retain or obtain a security interest in any property to secur~ any of the uabilities or any obligation hereunder; (b) retain or obtain the primary or secondary obligation of any obligor or obligors in addition to tho Undersigned, with respect to any of the liabilities; (c) extend or renew for one or more periods (whether or not longer than the original period). alter or exchange any of the Liabili1ies. or release or compromise any obligation of any of the Undersigned hereunder or any obligation of any nature of any other obligor with respect to any of the liabilities; (d) release its security interest in, or surrender, release or permit any substitution or oxchange for, aU or any part of any property securing any of the LIabilities or any obligation hereunder, or extend or renew for one or more periods (whether or not longer thon the original period) or release, compromise, alter or exchange any obligations of any nature of any obligor with respect to any such property: and (e) resort \0 tho Undersigned (or any of them) for payment of any of the liabilities. whether or not the Bank shall have rosorted to any property securing any of the Liabilities for payment of any of the Liabilities, or any obligation hereunder or. shall have proceeded against any other of the Undersigned or any other obligor primarily or secondarily obligated with respect to any of the Liabilities. Any amounts received by th9 Bank from whatsoever source on account of the liabilities may be applied by Bank toward the payment of such of the Uabillties and in such order of application. as the Bank may from time to time elect; and. notwithstanding any payments made by or for the account of the Undersigned pursuant to this Suretyship Agreement. the Undersigned shall not be subrogated to any rights of the Bank until such timo as this StJrotyship Agreement shall have been discontinued as to all of the Undersigned and the Bank shall have received payment of the full amount of allU.:lbilities and of aU obligations of the Undersigned hereunder. The Bank shall not be obligated under any theory of law relating to the marsnalHng of payment received or security interest granted under the terms of this Suretyship Agreement. HAR-29-06 WED 01:47 PH HTH SPECIAL ASSETS FAX NO, 717 255 2370 ( p, 07 'c I The Bank may. from time to time, whether before or after any discontinuance of this Suretyship Agrwment, without notice 10 the undersigned (or any of them), assign or transfer any or all tlf the Liabilities or any interest therein: and. notwithstanding any such assignment or transfer or <lny subsoquent assignment or transf&r thereof. sLlch Uabilities .shall be and remain Uabilities for the plIrpose of this Suretyship Agreement and et.:lch and every immediate and successive assigt1ee or transferee at any of the Liabilities or of any interest therein shall. to the extent of the interest of such assignoa or transferee. iI' the Uabilities. be entitled to the benefits of this Suretyship Agreement to the same extent as jf such assignee or transferee were the Bank: providod, however, th~t unless the Bank shall otherwise con.sent in writing, the Bank shall havs an unimpaired right prior and superior to that of any sllch assignoe or transferee. to enforce this Suretyship Agreement for the benefit of the Bank. as to those of the Liabilities which the Bank has nat ~5siunefl or tran~fBrred. No modification or waiver of any of the provisions of this Suretyship Agreement shall be binding upon the Bank except as expressly set forth in a writing duly signed by each of the Undersigned and the Bank. No action of the Bank permitted hereunder shall in any way affect or)mpalr the rights of the Bank and the obligation of the Undendgned under this Surety:s:h1p Agreement. For t"s purpose. of this Suretyship Agreement. Liabilities shall includo all obligations of the Borrower to the Bank, notwithstanding any right or power of tha Borrower or anyone else to &ssert any claim or defense a.s to tho invalidity or unenforceability of any such obligation and no such claim or defense shall affect or impair the obligations of the Undersigned horeundElf. The Liability of the Undersigned for Liabilities of Borrower incurred on or prior to the date hereof shall not exceed. at any time, the aggroga[o princ)p<JI amount of " 0 ($ 1,40, . ). plus mterest as stated in the evj onca of mde te ness given y Borrower toBiiik-w,d f1ftocm percent (15%1 attorneys' COmmiSSion; prOVided that this Suretyship Agreement ehall also be applicable 10 and extend to any and all LIabilities. plus interest and costs as aforesaid, of Borrower arising after the date hereof even if the total of such Uabilities plus the Liabilities outstandino on or prior to the date hereof exceed the aforementioned aggregate principal amOUnt. If no (imitation is inserted in this paragraph, thers is no limit to the liability of the UndC'!rsigned to the Bank. The creation or eJ(j.stence from time to tima of Uabilitles in excess of any amount to which the right of recovery under this Suretyship Aorcement is limited Is hereby authorized, without notice to the Undersigned (or any of them), and shall in no way affect or impair the right.! of the fJilnk and the obligation of the Undersigned under thi$ Suretyship Agreement. The Undersigned, jointly and severally, do hereby authorize and empOlMJ( any prothonotary or clerk or attorney of any court of r(lcord of Pennsylvania or elsewhere, to appear for and confess judgment against any or all of the Undersigned in favor of Bank for the total liability of the Undersignod os set forth herein together with interest thereon.. with or without declaration. with costs of suit, release of errors. without stay of execution or garnishment and with fifteen percent (15%) for collection fees, and waive the right of inquisition, and the benefit of all exemption laws now or hereinafter enilcted. and agree to condemnalion and the sale of real estate or personal property, or a writ of execution. In the event the Bank acquires any property securing this SlJretyship Agreement after a foreclosure sale as to real property or a public auction t.ale as to personal property, the Undersigned agrees to indemnify and hold the Bank harmless from any loss, costs. or expense Which tho Bank may &ust~in os a result of: la) Gelling the real or personal property so acquired for less than the total sums owed by the Borrower to the Bank. provided, howevor. that <my such sale by tho Bank IS dona in a commercially reasonable manner or (b) any action brought against the Bank under 9548 or S5401(b} or the United Slates Bsnkruptoy Code. as amended, on the ground that the consideratiol"'i paid by the Bank for the real or personal propel'ty was not -rair equivalent value. II within the contemplation of S544lb) or the United States Bankruptcy Code. as amended, or any applicablo stale ftaudlllent conveyance act. The Undersigned waive and release the Bank from any damages whIch the Undersigned may incur as a tesult of any intentional or llnint~ntional or negligent action or inaction of the Bank impairing, diminishing, or destroying any of the Undersigned's rights of subrogation which the Undersigned mny have upon payment of any of the Borrower's obligations. The Undersigned acknowledges previoLJsly having waived. under certain conditions, any sllch righu. The Undersigned hereby agrees that this Suretyship Agreement shalf apply to any obligation which the Bank may lncor as the result of [IOY payment to Bank by or on behalf of the Borrower which is determined to be a preference payment benefiting the undersigned. If a photostatic copy hereof shall have been filed in any of said proceedings, it shall not be necess.BIY to file the original as a warrant of attorney. The foregoing warrant and power 10 confess judgment Shall not be deemed to have been exhausted bV any single exercise theraof, whether or not any such exercise shall be held by any court to be invalid, voidable or void. but may be exercised from time to time. as often as the Bank shall aloct, until all .sums payable or that may become payable by each of the Undersigned have been paid in full. A subsequent guaranty or suretyship by the Undersigned or any other guarantor or surety of the Borrower's Liabilities given to tho Bank shall not be deemed to be In lieu of or to 6upersede or terminate this Suretyship Agreement but shalJ be construed to be additional or s\Jpplementaty unloss othorwise expressly provided therein; and in the eVent the Undersigned or any other guarantor or surety has given to the Bank a previous guaranty or Suretyship Agreement this Suretyship Agreement shall be construed to be additional or supplementary, and not to be in lieu thereof or to terminato such provious Suretyship Agreement, guaranty or guaranties unle5$ expressly so provided herein. This Suretyship Agreement shall be binding upon the Undersigned. and upon the heirs, legal representatives, successors and ilssigns of the Undersigned, and to ths extsnt that the Borrower Dr any of the Undersigned is an entity such as a partnership, limited partnership, limited liability company, corporation or any other similar entity, all references herein to the Borrower and to the Undersigned, respectively. shall be deemed to includo any successor or successors, whether immediate or remote, to such entity. If more than one party shall execute this Suretyship Agreement, tho term "UndersfgMdij as used herein shall mean all parties executing this Suretyship Agreement and each of them, and all such parties shall be joJntly and severally obligated hereunder. This Sllretyship Agreement sh~1I be construed in accordance with and governed by the laws of the CommonWealth of Pennsylvania without giving effect to choice of law rules. Wherever possible each provision of thi$ Suretyship Agreement shall be interpreted in such manner as to be effectivo and valid under applicable law but if any provision of this Suretyship Agreement shall be prohibited by or invalid undor such law, such provision shall be ineffective to the extel1t of suc.h prohibition or invalidity, without invalidating the remainder of such provjsion or the remaining provisions of this Suretyship Agreement. INTENDING TO BE LEGALLY BOUND HEREBY. the Undersigned have set their respective hands and seals the day and year first above wriUon. WITNESS UN ~. 'P<:T: (SURETY) L & L PARTNERS, LTD. Title: ~ ~ 8~~~~/~~/~ t Gene~al R~ ' , B~~__ ~~ ,te: General' Partner (SEAL) Title: (SEAL) ntla: B~ Title: (SEAL) 'bDi/<61 ~ 7/96 n t-<> ,::-:J c- r - ~ t ?\::) \0 ~ ~ ---- tt- :-.0 .~i) " "\ U") C:J - --...... 0 -.... ., r '" i -- Ii'- -u r', ~ ........ ~ ~ ...a ~ t.', ---.. ~ Qs- U .~ ~ ~ ~ ("--.. 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. () t!.,. 175"<;0 D J 1-1<<_ CONFESSION OF JUDGMENT MANUFACTURERS AND TRADERS TRUST COMPANY v. L&L PARTNERS, L TO Defendant NOTICE To: L&L PARTNERS, LTD., Defendant You are hereby notified that on ~ ;u:) ,2006. judgment by confession was entered against you in the sum of $159,631.70 in the above captioned case. Dated fYl';J./J ,L J..t , 2006 ~1d.f;,F!L" . Pro hon~~ 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. L&L Partners, Ltd. 100 Market Street Lemoyne, PA 17043 KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108.1963 MANUFACTURERS AND TRADERS TRUST COMPANY Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Diu. /'(')(., (;\/,I-Ier" v. L&L PARTNERS, L TO. CONFESSION OF JUDGMENT Defendant NOTICE L&L PARTNERS, LTD., Defendido Usted esta siendo notificando que el _ de del 2006, se anoto en contra suya un fallo por confesion en la suma de $159,631.70 en el caso men cion ado en el epigrafe. FECHA: ,2006 Prothonotary USTED DEBE LLEVAR IMMEDIATAMENTE ESTE DOCUMENTO A SU ABOGADO. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE A UNO, LLAME 0 VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRARASISTENCIA 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: L&L Partners, Ltd. 100 Market Street Lemoyne, PA 17043 ~d Attorney for Plaintiff(s) KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 MANUFACTURERS AND TRADERS TRUST COMPANY Plaintiff IN THE COURT F COMMON PLEAS OF CUMBERLAND OUNTY, PENNSYLVANIA CIVIL AC ION - LAW NO. 06-1 56 CIVIL TERM CONFES ION OF JUDGMENT v. L&L PARTNERS, L TO. Defendant PRAECIPE TO THE PROTHONOTARY: Please mark this judgment "Satisfied" by order of the Pia ntiff. KEEFER WOOD LLEN & RAHAL, LLP Date: May 30, 2006 By: Eugene E. Pepinsky, Jr. Attorney I D. #23702 210 Wain t Street P.O. Box 1963 Harrisbur ,PA 17108-1963 (717) 255 8051 Attorneys or Plaintiff o c; , <--' = C::.::J \':.,-.. 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