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Home My WebLink About06-2237 PaulL.' er, Esquire Attorney ID # 09603 300 Bridge Street, Second Floor P.O. Box B New Cumberland, P A 17070 (717) 920-8420 Attorney for Plaintiff WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - LAW JULIE A. KEIFER Defendant : NO. ()!r'c;J.;J37 CIVILTERM 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: $300.00 TOTAL $1,925.00 plus interest and costs of suit By: JULIE A. KEIFER Defendant :NO. CIVIL TERM WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - LAW AND NOW, this COMPLAINT IN CONFESSION OF JUDGMENT FOR MONEY 21c::.T' day of April, 2006, comes the Plaintiff, West Pennsboro Township Municipal Authority, by and through its attorneys, PaulL. Zeigler, 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, Julie A. Keifer, is an adult individual with a last known address of 106 A Street, Plainfield, Pennsylvania 17013 3. A true and correct copy of the Promissory Note and Disclosure Statement 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 00/100 ($1,625.00) plus reasonable attorney fees in the amount of Three Hundred and 00/100 ($300.00) for a total of One Thousand Nine Hundred Twenty five and 00/100 ($1,925.00) 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 Plaintiffby 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 this instrument 8. 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 One Thousand Nine Hundred Twenty five and 00/100 ($1,925.00) plus court costs, interest, and attorney's fees. Respectfully submitted, By: PaulL. Z gler, 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 21, 2006 PaulL. Ze er, squire Attorney ID # 09603 300 Bridge Street, Second Floor P.O. Box B New Cumberland, P A 17070 (717) 920-8420 Attorney for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on the 21 st day of April, 2006, I served a true and correct copy of the foregoing document by first class mail, postage prepaid, addressed as follows: Julie A. Keifer 106 A Street P.O. Box 205 Plainfield, PA 17013 By: Date: April 21, 2006 . . . ~>"h; b';tff . $ 1,625.00 October 21.., 2005 PROMISSORY NOTE FOR VALUE RECEIVED and intending to be legally bound, JULIE A. KEIFER, an adult individual with her principal address at 106 A Street Street, Plainfield, 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 (hereinafter "Obligee") the sum of One Thousand Six Hundred Twenty-Five and no/lOa ($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 olltstanding 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 payments 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 conseclltive 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 106 A Street, Plainfield, 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 due hereunder and then applied second to any outstanding principal payment due hereunder. Upon default hereunder and failure to cure within fifteen (IS) days of written notice thereof, Obligor further does hereby authorize and empower any attorney of any court of record of Pennsylvania or elsewhere to appear for her 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 errors. Judgment herellnder 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 unpaid balance or balances, and the judgment or jlldgments confessed shall be without stay of execution. Obligor specifically waives and releases any and all relief from any and all appraisement, stay or exemption laws of any state whether currently in force or hereinafter to be passed. WITNESS the due execution hereof this .iL day of October, 2005. WITNESS: "Obligor" -;J~ '-!!XL1P-~ri ADDRESS: 106 A Street, Plainfield, Pennsylvania 17013 DISCLOSURE STATEMENT The undersigned, having read this document in its entirety, and fully understanding it, hereby states, admits, acknowledges, and certifies the following: 1. I, as the Obligor, have this day signed a Promissory Note in which I promise to pay to WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY, the sum of One Thousand Six Hundred Twenty-Five and no/lOO ($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 formal 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 I own 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 reqllired to hire an attorney to file formal 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 suchjlldgment matter. 6. That I have an income, which is at least $10,000.00 per year. ADDRESS: 106 A Street, Plainfield, Pennsylvania 17013 WITNESS: \ \ , . ~ ~tH~~ "Obligor" DATE: October.2.L, 2005 -"-1 \... '- '''' 'V\ ~. "",) . ...) ~ ~ ~ lA , lA "'\ ;;: \i '" '~ ~ \ \ ~ ~. \ '\ "- .'" \. .-;.: ~ \J ~. '.~ . ~ ". ~ 'lI c,\ ,: ~ "" ..\ ~ "'''\ ~~~ U '\ , ' ,\ ~ tz . -' . , WEST PENNSBORO TOWNSHIP MUNICIPAL AUTHORITY Plaintiff : IN THE CO : CUMBERLA :PENNSYLVA T OF COMMON PLEAS COUNTY, IA v. -LAW JULIE A. KEIFER Defendant : NO. 06-2237 PRAECIPE TO SATISFY AND DISCONTINUE TO THE PROTHONOTARY: Dear Prothonotary: Please mark the above-styled action satisfied and dis By: Paul 1. e , Attorney # 09603 300 Bridg Street, Second Floor P.O. Box New Cum erland, PA 17070 (717) 920- 420 Attorney fi r Plaintiff Date: May 31, 2006 . . , ... ... ~ . . 'I CERTIFICATE OF SERVICE AND NOW, this 31st Day of May, 2006, I, Paul 1. Zeigler, quire, hereby certify that I have this day served the following persons with a copy of the foregoi g document, by first class, United States Mail, postage pre-paid, addressed as follow: Julie A. Keifer 106 A Street P.O. Box 205 Plainfield, P A 17013 By: gler, Esquire Attorney # 09603 300 Bridg Street, Second Floor P.O. Box New Cum erland, P A 17070 (717) 920- 420 Attorney r. r Plaintiff Date: May 31, 2006 .. - . o c;~ ~ "'" - -:''''' ::;. U) - C?, ::;1"", 0\r '"'oi::IJ. ~~) ~'( i_)\() -,~ ~~ -::J -,,~ ~ ~l?\ "J"- ':Q ~ - - v::>