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Home My WebLink About06-2364 . l' REAGER & ADLER, P.C. By: Theodore A. Adler, Esquire Attorney J.D. No. 16267 Email: Tadler(iiJReagerAdlerPC.com By: Thomas O. Williams, Esquire Attorney J.D. No. 67987 Email: Twilliams(iuReagerAdlcrPC.com By: Richard J. Joyce, Esquire Attorney J.D. No. 85520 Email: Rioyce(WReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EICHELBERGERS,INC., Plaintiff Case No. Ot,. J3L.'! c-~J v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Confession of Judgment Defendants CONFESSION OF JUDGMENT Pursuant to the authority in the Warrant of Attorney, the original or a copy of which is attached to the Complaint filed in this action, 1 appear for the Plaintiff and confess judgment in favor of Plaintiff and against both Defendants as follows: Principal Interest Collection Fees Total $54,325.91 $ 5,432.59 $19,720.00 $79,478.50 , I' Date: April olQ2006 -, ,...,,, .. REAGER & ADLER, P.C. By: Theodore A. Adler, Esquire Attorney J.D. No. 16267 Email: Tadler(cil.ReagerAdlerPC.com By: Thomas O. Williams, Esquire Attorney J.D. No. 67987 Email: Twilliams~i)Rea~erAdlerPC.com By: Richard J. Joyce, Esquire Attorney J.D. No. 85520 Email: Rioyce(@ReagerAdlerPC.com 2331 Market Street Camp Hill, P A 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA EICHELBERGERS, INC., Plaintiff Case No. (JIJ J-3f.. 'I Ci~j v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Confession of Judgment Defendants COMPLAINT IN CONFESSION OF JUDGMENT FOR MONEY 1. Plaintiff is Eichelbergers, Inc., a Pennsylvania corporation whose address is 107 Texaco Road, Mechanicsburg, Pennsylvania 17050. 2. Defendants are Quillen Development, Inc., the Maker of the Note under which Plaintiff has confessed judgment, and James P. Quillen, Jr., the Guarantor of the Note, whose addresses are 7 West Ridgley Road, Suite 100, Lutherville, Maryland 21093. 3. A true and correct copy of the Note under which Plaintiff has confessed judgment is attached hereto and marked Exhibit "A". 4. The Note under which judgment is being confessed has not been assigned. 5. The principal balance due under the Note is $54,325.91 plus interest of $5,432.59, together with collection fees of33% of these amounts as authorized by the Note for a total of$79,478.50. 6. The Defendants have defaulted under the Note. 7. Judgment has not been entered against either Defendant in any jurisdiction for the unpaid sum of$54,325.9l, of the interest of$5,432.59, or the collection fees of $19,720.00, for a total of$79,478.50 of the debt here demanded. 8. Judgment is demanded as authorized by the Warrant of Attorney contained in the Note attached as Exhibit "A". 9. The Warrant appearing in the attached Note is less than twenty (20) years old. WHEREFORE, Plaintiff demands judgment against both Defendants in the sum of $79,4 78.50, as authorized by the Warrant appearing in the attache:d Note, together with interest from the date of judgment and costs. Respectfully Submitted, Date: April oiL{ 2006 NON-NEGOTIABLE PROMISSORY NOTE W1TH GUARANTEE Mechanicsburg, P A 'I.::rj-i 2 t. ~:"'(,:::, L.... " , '-'...'.1.., Note Amount: $54.325.91 February 2006 For Value Received, Quillen Development, Inc., hercinafter "Maker", agrees to pay to the order of Eichelbergers, Inc., 107 Texaco Road, Mechanicsburg, P A 17050 or at such other place as the holder hereof may from time to timc direct, a certain trade indebtedness in the amount of FIFTY-FOUR THOUSAND THREE HUNDRED TWENTY-FIVE AND 91/100 DOLLARS ($54,325.91) owed to Payee in lawful money ofthc Unitcd States of America, in accordance WIth the following terms: 1. as follows: Repavment. Maker shall repay the balance due under this Note in installments N\1<J,)o-.\~ ~ a. Tim.e: Payment of$15,000 to be made on Friday, F'eblUmy 24,.2006 and subsequent monthly payments due on the last day of cach month commencing on Marcl, 31, 2006, of principal and interest, each in the amount of$10,000.00, until paid in full. 2. Interest Rate. Interest shall accrue from the date hereof on the principal amount outstanding hereunder, from time to time, at the rate of 10% per annum. 3. Application ofl'ayrnent. All payments made under this Note shall be applied first to late payment charges or other sums owed: to Payec, ncxt to accrued and unpaid mterest, if any, and the balance to the repayment of principal arising from the unpaid invoice for materi al supplied at the ear.liest date, provided that no principal payment shall be applied to an invoice for which t11el'e exists an enforceable payment bond until all non-bonded invoices are paid in full. 4. Prepayment. Maker may prepay this Note in whole or in part at any time, without penalty. 5. Default and Remedies. If the Maker shall fail to make any payment of principal or interest due hereunder on or before its due date, which failure continues for a period often (10) days after written notice, the Payee shall be entitled to receive a late charge equal to five percent (5%) on the amount of the unpaid payment as a late payment penalty. If any payment is not made within ten (10) days after written lloticc, such nonpayment shall constitute a Default hereunder, notwithstanding the payment oflate charges hereunder, and shall entitle Paycc to all of the rights and remedies specificd herein, or otherwise available under applicable law, without notice, any right to cure, or obligation to make demand for paym.ent, except as specifically required herein. Upon a Default, the entire unpaid principa.l balance of this Note togethcr with all accrued but unpaid interest and other sums due hereunder, shall immediately become due and payable in full and Payee shall have the right to bring suit for such amount and exercise any other rcmedies available, and Maker does hereby authorize any Clerk of any COllli of Record in Pennsylvania or elsewhere to enter judgment by confession against it in favor of the I holder of this Note for the full amount ofthe indebtcdness due hereunder, to inchtde interest, costs and actual attomeys fees, expressly waiving summons and other process, and does further consent to the immediate execution of said judgment, expressly waiving the benefit of any homestead or other exemption laws. Payee may also exercise any or aU other rights, powers or remedies it may have or which shall now or hereafter exist at law or in equity. 6. Attorney/Collection Fees Payable. Should Eichelbergers, Inc. refer any past-due balance 10 any attorney or collection agency for colkctiol1 efforts, Debtor agrees to pay, upon demand, a collection fee equal to 33% of any sums due from Debtor togethcr with any other fccs, costs or expenses incuned to coUcct the past-due balancc, including court costs. This document and all disputes snall be governed by the Jaws of the State of Pennsylvania. 7 Certain Actions by Payces Shall Not Constitute Waiver. Failure of Payee to exercise any right hereunder shall not constitute a waiver or right to exen;ise thc same or any other right at any subsequent time, and no single or partial exercise of any right or remedy shall preclude other or further exercise ofthe same or any other right or remedy. The acceptance by Payee of any payment hereunder that is less than payment in full of all amounts due and payable at the time of such payment shall not constitute a waiver ofthe right to cxercise any option hereunder at that time or at any subsequent time, or nullify any prior exercise of any such option without the express written consent of Payee. Payee does not waive, surrender or impair any of its rights under any statute, bond or rnechamcs lien by acceptan.ce of this promissory note, or the receipt and acceptance of any payment, except as such payment, after application of payments in the order provided for herein, extinguishes the Debt Maker acknowledges that Payec retains all of its rights to collect the amounts clue it and to assert such claims or liens as it has in each case. 8 Waivers bv Maker. Except for the notice requirements amd cUr~ periods providcd for herein, Maker waives presentment, protcst, demand and notice of dishonor, demand for payment, notice of protest, nonpayment and all other matters or notices of a like nature. 9. Expenscs of Collection. In th~ event that Maker is in Default under the terms of this Note, Maker agrees to reimburse payee immediately upon demand for the full amount of actual a.ttorneys fees and court costs, if any, incurred by Payee in connecti On with the enforcement or collection of this Note. 10. Choice of Law. This Note is made in the State of Pennsylvania and shall be constmed and enforced in accordance with the laws ofthe State ofPennsylvallia. 2 " ! IN WITNESS WHEREOF, the Maker has caused this NClle 10 be executed in its name. MAKER: QUILLEN DEVELOPMENT, INC. Attest: ~~~/ By: Gu.arantee of James P. Ouillen. Jr. All payments to be made by Maker \mder and by the terms ofthis Promissory Note are guaranteed by .lames P. Quillen, Jr. '7 q <. --- ~ Oh Witness: ~) James P. 3 . VERIFICATION I, James A. Baird, hereby verify that I am the Vice President of Finance and Controller of Eichelbergers, Inc., and, as such, I am authorized to verify the averments of the foregoing document are true and correct to my personal knowledge, information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 34904, relating to unsworn falsification to authorities. Date: 4 JtS} 0(. BY:~ Q.U James A. Baird, Vice President ofPinance and Controller ~. ~ ~ '$.. .'u '- -.J ..J " ~ "- '-.l , l-v .) .J - " '- ~ " \ ~\ ~ . v- ('., ,\ " .-' ("<, , .\ _,"-1, \F'~\ 0> v '::c..,,,, - ~, k, , ~ . '" ~~>-' - \~ "tl "r .' --\ '-.J "-. v --.J "- . . ,~ / / .i REAGER & ADLER, P.C. By: Theodore A. Adler, Esquire Attorney LD. No. 16267 Email: Tadler(iilReagerAdlerPC.com By: Thomas O. Williams, Esquire Attorney LD. No. 67987 Email: Twilliams((zJReagerAdlcrPC.com By: Richard J. Joyce, Esquire Attorney LD. No. 85520 Email: Rioyce(iiJ.ReagerAdlerPC.com 2331 Market Street Camp Hill, P A 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA EICHELBERGERS, INC., Plaintiff Case No. t%- ,,;J3{..f( CttJ v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Confession of Judgment Defendants PRAECIPE FOR ASSESSMENT OF DAMAGES AND CONFESSION OF JUDGMENT TO THE PROTHONOTARY: Pursuant to the Warrant of Attorney contained in the Note, a copy of which is attached to the Complaint filed in this action, I hereby confess judgment in favor of the Plaintiff and against the Defendants and assess damages as follows: Principal Interest Collection fees at 33% as authorized by the Note Total $54,325.91 $ 5,432.59 $19,720.00 $79,478.50 '....- ~ J' , , 1 Respectfully Suh~itted, Date: April c1), 2006 .-..' .-t ;)'1 REAGER & ADLER, P.C. By: Theodore A. Adler, Esquire Attorney J.D. No. 16267 Email: Tadler(iVReagerAdlcrPC.com By: Thomas O. Williams, Esquire Attorney J.D. No. 67987 Email: Twilliams((vReagerAdlerPC.com By: Richard J. Joyce, Esquire Attorney J.D. No. 85520 Email: Riovce(ci!ReagerAdlerPC.com 2331 Market Street Camp Hill, PA l701l Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EICHELBERGERS, INC., Plaintiff Case No. vt,. 7?(..li {,UJ! v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Confession of Judgment Defendants ENTRY OF APPEARANCE TO THE PROTHNOTARY: Enter my appearance for the above-named Plaintiff pursuant to the Warrant of Attorney attached hereto. Date: April do' 2006 " .-.\ I~' 1 .. REAGER & ADLER, P.C. By: Theodore A. Adler, Esquire Attorney J.D. No. 16267 Email: Tadler@ReagerAdlerPC.com By: Thomas O. Williams, Esquire Attorney J.D. No. 67987 Email: Twilliams((ilRcagerAdlerPC.com By: Richard J. Joyce, Esquire Attorney I.D. No. 85520 Email: Rioyce(@ReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA EICHELBERGERS, INC., Plain tiff Case No. tit- ;)3 (;.1/ c~j v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Confession of Judgment Defendants TO: James P. Quillen, Jr., Defendant You are hereby notified that on April dl , 2006, judgment by confession was entered against you in the sum of$79,478.50 in the above-captioned case. Date: ~J d-I, ,:}f:ffp }5i t<vt. K ~1;;' Prothonotary /.<'? L> YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Courthouse, 4th Floor Carlisle, PA 17013 (717) 240-6200 .. , I hereby certify that the following is the address of the Defendant stated in the Certificate of Residence: 7 West Ridgley Road, Suite 100 Lutherville, MD 21093 A , Demandado( s) REAGER & ADLER, P.C. By: Theodore A. Adler, Esquire Attorney J.D. No. 16267 Email: Tadler(ciJReagerAdlerPC.com By: Thomas O. Williams, Esquire Attorney J.D. No. 67987 Email: Twilliams((i)ReagerAdlcrPC.com By: Richard J. Joyce, Esquire Attorney J.D. No. 85520 Email: Riovce(ciJReagerAdlerPC.com 2331 Market Street Camp Hill, P A 170 II Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EICHELBERGERS, INC., Plaintiff Case No. 0(.:" ,')3(.-'1 v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Defendants Confession of Judgment AFFIDAVIT THAT THE JUDGMENT IS NOT BEING ENTERED BY CONFESSION AGAINST A NATURAL PERSON IN CONNECTION WITH A CONSUMER CREDIT TRANSACTION Commonwealth of Pennsylvania ) ) ss: County of Cumberland ) I, Richard J. Joyce, being duly sworn according to law, hereby state that the judgment being entered by confession is not being entered against I person in connection with a consumer credit transaction.~ Name: Sworn to and subscribed Before me this ;?o 'lLday of r' , 200k. Member, Pennsylvania Associalion 01 Notaries {W j " REAGER & ADLER, P.C. By: Theodore A. Adler, Esquire Attorney J.D. No. 16267 Email: Tadlcr(ZvRcagcrAdlerPC.com By: Thomas O. Williams, Esquire Attorney J.D. No. 67987 Email: Twilliams({vReagcrAdlcrPC.com By: Richard J. Joyce, Esquire Attorney J.D. No. 85520 Email: Rioycc(liJ.RcagcrAdlcrPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA EICHELBERGERS, INC., Plaintiff Case No. tit- 'd-Jt..-t( v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Confession of Judgment Defendants AFFIDAVIT OF NON-MILITARY SERVICE Commonwealth of Pennsylvania ) ) ss: County of Cumberland ) The undersigned, being duly sworn according to law, deposes and says that the , c';J; Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions ofthe Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended: , ,... That James P. Quillen, Jr. is more than 18 years of age and resides at 7 West Ridgley Road, Suite 100, Lutherville, MD 21093. Sworn to and subscribed Before me this ,AD 1'- day of fJ;)r, I ,200L ~.bVZ. Notary ryublic TH P f' V VANIA Notarial Seal Monica D. Zercher. Notary Public Camp Hill Bora. Cumberland County My CommiSSIOn Expires Feb. 8. 2010 Member. Pennsylvania Association of Notaries .-" REAGER & ADLER, P.c. By: Theodore A. Adler, Esquire Attorney LD. No. 16267 Email: Tadler(cvReagerAdlerPC.eom By: Thomas O. Williams, Esquire Attorney LD. No. 67987 Email: Twilliams(cvRcagerAdlerPC.com By: Richard J. Joyce, Esquire Attorney LD. No. 85520 Email: Riovce(a)ReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EICHELBERGERS, INC., Plaintiff ~J Case No. tJt. ~:23 &I-( v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Confession of Judgment Defendants NOTICE UNDER RULE 2958.3 OF JUDGMENT AND EXECUTION THEREON NOTICE OF DEFENDANT'S RIGHTS TO: Quillen Development, Inc. and James P. Quillen, Jr. A judgment in the amount of$79,478.50 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 on other paper allegedly signed by you. The Court has issued a writ of execution which directs the Sheriff to take your money or other property owned by you to pay the judgment. If your money or property has been taken, you have the right to get the money or property back if you did not voluntarily, intelligently and knowingly give up your constitutional right to notice and hearing prior to the entry of judgment or if you have defenses or other valid obj ections to the judgment. You have a right to a prompt court hearing if you claim that you did not voluntarily, intelligently and knowingly give up your rights to notice and hearing prior to the entry of the judgment. If you wish to exercise this right, you must immediately fill out and sign the Petition to Strike the Judgment which accompanies the Writ of Execution and deliver it to the Sheriff of Cumberland County at Carlisle, Pennsylvania. IT IS IMPORTANT THAT YOU ACT PROMPTLY. IT WILL BE TOO LATE TO REGAIN YOUR PROPERTY IF YOU WAIT UNTIL AFTER THE PROPERTY HAS BEEN SOLD BY THE SHERIFF OR TURNED OVER TO THE PLAINTIFF. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 Respectfully Submitted, Date: April 020, 2006 ~ - REAGER & ADLER, P.c. By: Theodore A. Adler, Esquire Attorney J.D. No. 16267 Email: Tadler@ReagerAdlerPC.com By: Thomas O. Williams, Esquire Attorney J.D. No. 67987 Email: Twilliams@ReagerAdlerPC.com By: Richard J. Joyce, Esquire Attorney J.D. No. 85520 Email: Riovce@ReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EICHELBERGERS, INC., Plaintiff Case No. 0'" - ;)3,"4 Li::J v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Confession of Judgment Defendants PETITION TO STRIKE JUDGMENT REQUEST FOR PROMPT HEARING I hereby certify that I did not voluntarily, intelligently and knowingly give up my right to notice and hearing prior to the entry of judgment. I petition the Court to strike the judgment on this ground and request a prompt hearing on this issue. I verify that the statements made in this Request for Hearing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. , . Dated: Dated: Notice of hearing should be given to me at: Quillen Development, Inc. 7 West Ridgley Road, Suite 100 Lutherville, MD 21093 And James P. Quillen, Jr. 7 West Ridgley Road, Suite 100 Lutherville, MD 21093 Quillen Development, Inc., Defendant James P. Quillen, Jr., Defendant (-- ,.,-" ~..~-..- r ( ,) (f". REAGER & ADLER, P.C. By: Theodore A. Adler, Esquire Attorney J.D. No. 16267 Email: Tadlcr(cilReagerAdlcrPC.eom By: Thomas O. Williams, Esquire Attorney J.D. No. 67987 Emai1: Twilliams(cilReagerAdlerPC.com By: Richard J. Joyce, Esquire Attorney J.D. No. 85520 Email: Rioyee(cilReagerAdlerPC.com 2331 Market Street Camp Hill, P A 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EICHELBERGERS, INC., Plaintiff Case No. ot. . ;')7,(.;,/ r..'WJ v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Confession of Judgment Defendants CERTIFICATION OF ADDRESSES TO THE PROTHNOTARY: The address of the Plaintiff, judgment creditor, is 107 Texaco Road, Mechanicsburg, Pennsylvania 17050, and the last known address of the Defendants, judgment debtors, is 7 West Ridgley Road, Suite 100, Lutherville, Maryland 21093. Date: April JIJ, 2006 ('- :\ '\ REAGER & ADLER, P.C. By: Theodore A. Adler, Esquire Attorney J.D. No. 16267 Email: Tadler(ivReagerAdlerPC.eom By: Thomas O. Williams, Esquire Attorney J.D. No. 67987 Email: Twilliams(ZvReagerAdlerPC.com By: Richard J. Joyce, Esquire Attorney J.D. No. 85520 Email: Rioyce(wReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA EICHELBERGERS, INC., Plaintiff Case No. /)Lo.. J.3 {"t( (.~J v. QUILLEN DEVELOPMENT, INC. And JAMES P. QUILLEN, JR., Coufessiou of Judgment Defendants CERTIFICATION I hereby certify that: (a) This Praecipe is based upon a Judgment Entered by Confession, and (b) Notice will be served with a Writ of Execution Pursuant to Rule 2958.3. Respectfully Submitted, Date: April olD, 2006 " .--~ \,~"- .\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Eichelbergers, Inc. Plaintiff, ) ) ) ) ) ) ) ) CASE NO. 06-2364 Civil vs. James Paul Quillen, Jr. Defendant( s). SUGGESTION OF BANKRUPTCY COMES NOW the Defendant, James Paul Quillen. Jr. , through his/her undersigned attorney, and would show the Court: 1. He/She has filed a petition for relief under Title 11, United States Code, in the United States Bankruptcy Court for the District of Maryland, which bears the case number 06-15938. 2. Relief was ordered on September 26.2006. 3. This action is founded on a claim from which a discharge would be a release or that seeks to impose a charge on the property of the estate. 4. This is for informational purposes only, and does not constitute a notice of appearance by the undersigned. WHEREFORE, the defendant suggests that this action has been stayed by the operation of 11 U.S.C. ~ 362. r::: s Ro d J Drescher Ro d J Drescher Dr scher & Associates, P .A. eservoir Circle, Suite 107 altimore, MD 21208 (410) 484-9000 Attorney for Defendant IT IS HERBY CERTIFIED that a copy of the foregoing Suggestion of Bankruptcy was delivered by mail this October 16. 2006 to: Theodore Adler, Esquire, Reager & Adler, P.C., 2331 Market Street, Camp Hill, P A 17011 /s/ Ronald J Drescher Ronald J Drescher Attorney for Defendant Software Copyright (cl 1996-2004 Best Casa Solutions, Inc. - Evanston, Il - (800) 492-8037 Best Case Bankruptcy (') c < -oi.L rprr: ...:;..-,-" --:;1' r'."' c).))::" ~~~, s;f~ ~ =< ~ = = CT'> o c-.> --t N o V :!, o " =2 rn:D -ohi -uL"J _;,.., T ~O -1-""" (') :!J -'7("') OfTl ;r;! :0 -< w .. c..n .-