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Home My WebLink About06-2706 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Starview Sales, Inc. Plaintiff No. ()~ -';).76Co C/(-'tC~/L1-I'\ v. Confession of Judgment Donna M. Crider and Richard D. Crider Defendants Complaint Pursuant to Pa.R.Civ.P. 2952 WARRANT OF ATTORNEY Pursuant to the authority contained in the warrant of attorney, a copy of which is attached to the Complaint filed in this action, I appear for Defendants Donna M. Crider and Richard D. Crider, and confess judgment in favor of Plaintiff Starview Sales, Inc. and against Defendants Donna M. Crider and Richard D. Crider as follows: Principal sum: $52,331.40 (including loan fee of $1 ,200.00) Interest: $1,008.62 through May 12,2006, with interest thereafter accruing at a daily rate of $11.21. Attorney fees: $7,849.71 Total: $61,089.73, plus accruing daily interest and costs of suit. Respectfully submitted, ~& John L. Senft, Esquire Attorney LD. No. 64486 Senft Law Firm LLC 105 Leader Heights Road, Suite 2 York,PA 17403 Attorneys for Plaintiff Starview Sales, Inc. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Starview Sales, Inc. Plaintiff No. DL~ -;;;2 7 60 C/~LttL~/L~ v. Confession of Judgment Donna M. Crider and Richard D. Crider Defendants Complaint Pursuant to Pa.R.Civ.P. 2952 COMPLAINT IN CONFESSION OF JUDGMENT 1. Plaintiff is Starview Sales, Inc., a Pennsylvania corporation, whose address is 4775 N. Sherman St. Extended Mt. Wolf, PA 17347. 2. Defendants are Donna M. Crider and Richard D. Crider, husband and wife, adult individuals who live at 47 Fleicher Road, Marysville, PA 17053. 3. Attached to this Complaint as Exhibit A is a true and correct reproduction of the original of a Judgment Note signed by Defendants, dated February 11, 2006, in the sum of $51,131.40, on which this confession of judgment is based. 4. Judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. 5. Judgment on Exhibit A has not heretofore been entered in any jurisdiction. 6. Exhibit A has not been assigned. 7. There is no requirement that judgment may be entered only after a default or the occurrence of a condition precedent. ,. 8. An itemized computation of the amount due is as follows: a. Principal sum due: $52,331.40 (including loan fee of$1,200.00) b. Interest: $1,008.62 through May 12,2006, with interest thereafter accruing at a daily rate of $11.21. c. Attorney fees: $7,849.71 Total: $61,089.73, plus daily interest and costs of suit. 9. Judgment in favor of Plaintiff and against Defendants is demanded as authorized by the warrant of attorney filed in connection with this Complaint. 10. The instrument is less than twenty years old, and a copy is attached hereto; no application for a Court Order granting leave to enter judgment after notice is required. Wherefore PlaintiffStarview Sales, Inc. demands judgment in the sum of$61,089.73 in its favor and against Defendants Donna M. Crider and Richard D. Crider individually and jointly, plus continuing interest and costs. Respectfully submitted, ~~~ Attorney LD. No. 64486 Senft Law Firm LLC 105 Leader Heights Road, Suite 2 York, PA 17403 Attorneys for Plaintiff Starview Sales, Inc. 2 . :::6 ':38'M Se n f t Law No.2163 p, 4 , , " a~.l't..~criti(:s. ,! I :.'11 ! , ~ :1" .' , '!, ., VERIFICATION .,".. . '," , :.:.....~';~.l.. ;,';'-:'::" , ,.f.... :iereby verify that the fa.cts set forth in the foregoing Complaint are true and comet to .,' ". '. . :W.H~:~ ,"bjc:ct to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to ~~ :: ~f':, ' .!; . ~ ""'\..,...~. .:.....'1:........ I I . I ',I i . I ~ I '! :1 " . J , .j :'1' . :1 I :1 I 1 ; j II 'f' I I , . , 1:13 39\1d 1HE991: 81:91 913131:/813/90 84/28/2866 12:47 2663111 PAGE 62 ~tO:rg&tic",J .. ::" .:: JUDGMEI'S'T NOTE Ln, {3t.l/O On demand after date,'! promise to pay to the order of )t"l"'VIPw Sill.....; ~ the , , ..-.t.. ~~~ stUD of fI':J ~ rl'Jt"r..(l..,..,.~~ without defalcation, value received with interest at the rate of .aercent due ljI1d payable in ~ t1 t:J...r. 6)1 fiplM '/.1'1 ~ '<'" '" ~ 0.. Ji;,o fe""~""" 1-,14"" (',., "t. !;PJtJO T.6.. f'-1id.,1' e ",of. + re....., . ...., a <=> ~ And further I do hereby authorize and empower the Prothonotary or any Atto~i ~ :;l '. ~."'. f'T1 fti,.~::!:l I'q ': r:;:J of any Court of Record of Pennsylvania or elsewhere to appear for and enter jud~eiij _ ex ~ .;:- 6.Q. against me for the above sum, with or without declaration with costs of suit and ~ ?:, ~ g~ . .:$:~ _ om "'" ,. :);! attomey's commission of fifteen (15%) percent added for collection and release of~ ~ ~ ~. b 11)~~d" Date errors without stay of execution; and I hereby agree not to make any motion or any application whatsoever to any Court for an inquisition on any real estate that may be levied upon to cOllect the aforesaid sum, and I voluntarily condenm same, and authorize the Prothonotary to enter said voluntary condemnation upon the Writ of ExecutiOll. I . further agree that any property, real, personal or mixed, may be sold through a Writ of Execution 'and further waive and release all relief from any and all appraiscments, stay or exemption laws of any State now in force or which are passed hereafter. e~-etl-~ /Lj,,1-f6 'Si{wJ....w_~,,~~s. J;~c 3J,t:!)/:) 0 , 1~1'>I.iI~ fe, .}l>s1."I.> c.l>IC(~'" I ~5- '.!'-S-?7~ . IV.""~ {oV' :> 7' EXHIBIT I A I 04/20/2005 12:47 2553111 " PAGE 03 .'W~R IN EXECUTING nus NOTE, I UNDERSTAND THE TRANSACTION, AND KNOWINGLY AND VOLUNTARILY WAIVE MY RIGHTS TO CONSENT THE ENTRY OF TIllS JUDGMENT AGAINST ME IN COURT, AND DO HEREBY CONSENT TO THE ENTRY OF TIiIS JUDGMENT BY CONFESSION, -t. '-.., F"I foLV (VJb "f"1'f4'J~ 10 Witness my hand and seal, Signed, Sealed and Delivered ii1 the Presence of: . /J .A/ftIL 5:1 ~~ bOMV, It. (!i(tOrx... ff~/J,~ Signature !. IcJI.A1(D () &(11)f!Jt. ~? r/~/C~1J;1 II{ .U4'"'t&I'('-~ Address 11~3 . . ?/Z t9P/-<5'Y~ Phone # 1'- I - ~ -?' - Q..t;; go .<. D e-<(/7 ~ SS# /{/I- '-(<.{ ~ ~C.II /),k (!n.tR!tS\:.. wi.n - ~ \.fl,tu. . W' ess J e,.t'r..... fbiif' S~ Commonwealth of Pennlylvanla) tt )--1.. OOUntyof l-i_ L" /""'1 ) Swona IlId SublCl'fbe4 to lIefore me ~1/;/2006 OD rf- lIS ~~ NoWy I'lrb Ie I.J~a", ~ /,..LVI '^I.- - NOTARIAL SEAL I JEAN BURSON, NOTARY PUBLIC CITY OF ENOlA,CUMBERLAND COUNTY MY COMMISSION EXPIRES JAN. 18, 2007 . , Q ,...., R, "-,, c = C ? Cf' N ~ ~ --0 ~:S:,~ :::a:. ~~ f11fT, ~ 1- - Z-,':C' ~ ~ ....0 mC;~.,;: - ~~. , - vt ;:0: f'- ...... ~:'('} "'0 ~J: :0 r "- ~ c> :::J' U~ "" (, Z j :J>C: <? 0 ~ "" ~ - ~ Ut ~ IU' ~ c.:> -, 1 ~- ---. ("'> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Starview Sales, Inc. Plaintiff v. No. a. -J,.1Cb (?;<-J{C-T02-~ Donna M. Crider and Richard D. Crider Defendants Confession of Judgment Complaint Pursuant to Pa.R.Civ.P. 2952 NOTICE OF ENTRY OF JUDGMENT, ORDER, OR DECREE TO: DONNA M. CRIDER 47 Fleicher Road Marysville, PA 17053 PURSUANT TO PA. RULE NO. 236, YOU ARE NOTIFIED THAT THERE WAS ENTERED IN THIS OFFICE TODAY, IN THE ABOVE-CAPTIONED CASE: xx Judgment of$61,089.73, plus interest and costs of suit, for Plaintiff and against Defendants Donna M. Crider and Richard D. Crider Dated: {Y{.;J d / / ~ OD b t f PRtftof!Ji; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Starview Sales, Inc. Plaintiff v. No. C>~ - ;)^f6b Cl'LJl.t-Tf/L~ Confession of Judgment Donna M. Crider and Richard D. Crider Defendants Complaint Pursuant to Pa.R.Civ.P. 2952 NOTICE OF ENTRY OF JUDGMENT, ORDER, OR DECREE TO: RICHARD D. CRIDER 47 Fleicher Road Marysville, P A 17053 PURSUANT TO P A. RULE NO. 236, YOU ARE NOTIFIED THAT THERE WAS ENTERED IN THIS OFFICE TODAY, IN THE ABOVE-CAPTIONED CASE: xx Judgment of $61 ,089.73, plus interest and costs of suit, for Plaintiff and against Defendants Donna M. Crider and Richard D. Crider Dated: fYl'::J'-{ I ~ .2DDb PRfI:.'o~ " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA W Starview Sales, Inc. Plaintiff No. 06-2706 v. Confession of Judgment Donna M. Crider and Richard D. Crider Defendants Complaint Pursuant to Pa.R.Civ.P, 2952 NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON ********************* NOTICE OF DEFENDANTS' RIGHTS TO: DONNA M. CRIDER RICHARD D. CRIDER 47 Fleicher Road Marysville, PA 17053 A judgment in the amount of $61,109.23 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 th~.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 MA Y 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: Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 717-249-3166 John L. Senft, Esquire Attorney LD. No. 64486 Senft Law Firm LLC 105 Leader Heights Road, Suite 2 York, PA 17403 Attorneys for Plaintiff Starview Sales, Inc. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this II day of May, 2006, I served the foregoing Notice upon Defendants by U.S Mail, postage prepaid, addressed as follows: DONNA M. CRIDER RICHARD D. CRIDER 47 Fleicher Road Marysville, P A 17053 ~ ~ -.,1. ....:> <-= = c:J" ~ ~ :r! rn:n -ogj -") 1 ;~~O -'-jl ::r:." 0- c~,.Q ~l" ~ """',,;... r -< \.0 -0 ::;;: en .11 STARVIEW SALES, INC., 4775 North Sherman Street Extended Mt. Wolf, PA 17347, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2006-2706 CNIL TERM DONNA M. CRIDER RICHARD D. CRIDER 47 Fleicher Road Marysville, P A 17053, Defendants PRAECIPE FOR WITHDRAWAL OF COUNSEL AND APPEARANCE OF COUNSEL TO THE PROTHONOTARY: Please note my withdrawal as counsel for Starview Sales, Inc., Plaintiff in the above matter. Dated: .l( 2-,fOJ SENFT LAW FIRM, LLC ~L~Ek~~ LD. # 64486 Senft Law Firm, LLC 105 Leader Heights Road, Suite 2 York, Pennsylvania 17403 BY: Kindly enter our appearance on behalf ofStarview Sales, Inc., Plaintiffin the above matter. Dated: }-/7 r 107 I t David A. Baric, Esquire LD.# 44853 19 West South Street Carlisle, PA 17013 (717) 249-6873 BY: Attorney for Plaintiff 01 ..II CERTIFICATE OF SERVICE I hereby certify that on this date, a true and correct copy of the foregoing Praecipe for Withdrawal of Counsel and Appearance of Counsel was served by first-class mail, postage prepaid, upon the following: Dated: 0/ J {p / )J.i)01 , Donna M. Crider Richard D. Crider 47 Fleicher Road Marysville, Pennsylvania 17053 ~. Bdlluk Andrea M. arrick, Secretary o c ...,.. <':.0" """C1 tt: n"Hl' ~'0~" Cf) "" ~t::,' ~f:~." :;;.-c z :2 ~ c::> c::> --' :x ~ N N -0 ';'Ii: Y! (...) -J ~ ~-n rt"fu ~9 ~:~~, -:-:1; :tt (;";0 ,,~- ,n g ~ II \ ' " ST ARVIEW SALES, INC., 4775 North Sherman Street Extended Mt. Wolf, PA 17347, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2006-2706 CIVIL TERM DONNA M. CRIDER RICHARD D. CRIDER 47 Fleicher Road Marysville, P A 17053, Defendants PRAECIPE TO SATISFY TO THE PROTHONOTARY: Kindly mark the judgment in the above-captioned action as having been satisfied. Respectfully submitted, EN'B~C~ David A. Baric, Esquire LD. 44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff dab.dir/litigation/starviewsales/satisfy-cum berland. pra \. ~ CERTIFICATE OF SERVICE I hereby certify that on March 11 ,2007, I, David A. Baric, Esquire of O'Brien, Baric & Scherer, did serve a copy of the Praecipe To Satisfy, by first class U.S. mail, postage prepaid, to the party listed below, as follows: John W. Purcell, Jr., Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, Pennsylvania 17102 David A. Baric, Esquire g -,.. :s- v\~ rn r ~~~: ':2.;-": (n " -< ' ~ '~C"~ ~(::: PC z =<! ~ c::> --J ::& ::t>'" ::;0 N N ~ 5!.." m, ,,- =89 ()6 ~...-. :C-h '~;j ('5 om .::cj ?E ;..,: -0 3 o .s::'" .1':-