HomeMy WebLinkAbout06-6899GDW, LLC,
Plaintiff,
v.
WARREN SCOTT and
RICHARD BUTLER,
individually and d/b/a
Your Hair Station,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. G (~ - 'p a '7~l C.1 v 1 ( I c sr.
CIVIL ACTION-LAW
CONFESSION OF JUDGMENT
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the warrant of attorney, the original or a copy of
which is attached to the complaint filed in this action, I appear for the defendants and confess
judgment in ejectment in favor of the plaintiff and against the defendant for possession of the real
property described as follows: 34 North Corporation Street, Suite 2, Newville, Cumberland
County, Pennsylvania 17241.
~~~
Attorney for Defendants
~ ^~'
~ o !~
~.. ~-'
r~
~
:>
- ' „'~ ~ r~-
~
` .~
~ _~ V
~
_-~ i4
"'~ f
-
~ .~- s~
J i
-+
N ~
..,, -,~
GDW, LLC,
Plaintiff,
v.
WARREN SCOTT and
RICHARD BUTLER,
individually and d/b/a
Your Hair Station,
Defendants.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
CONFESSION OF JUDGMENT
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by an attorney and filing in writing with
the court, your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so, the case may proceed without you and a judgment may be entered against you
by the. court without further notice for any money claimed in the complaint or for any other claim
or relief requested by the plaintiff. You may lose money or property or other rights important to
you.
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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
GDW, LLC, ;
Plaintiff, :
v.
WARREN SCOTT and
RICHARD BUTLER,
individually and d/b/a
Your Hair Station,
Defendants. :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
CONFESSION OF JUDGMENT
COMPLAINT IN EJECTMENT
NOW, comes Plaintiff, GDW, LLC, by and through its attorneys, O'BRIEN, BARIC &
SCHERER, and files the within complaint and, in support thereof, sets forth the following:
1. GDW, LLC, is a Connecticut limited liability company with an address of 15
Whitehall Pond, Mystic, Connecticut 06355
2. Plaintiff owns and operates a commercial building located at 34 North
Corporation Street, Newville, Cumberland County, Pennsylvania 17241.
3. Defendants, Warren Scott and Richard Butler are adult individuals who do
business as Your Hair Station located at 34 North Corporation Street, Suite #2, Newville,
Cumberland County, Pennsylvania 17241.
4. On or about September 1, 2005, Warren Scott and Richard Butler executed a
Commercial Lease Agreement with Plaintiff. A true and correct copy of the Commercial Lease
is attached hereto as Exhibit "A" and is incorporated by reference.
5. Defendants took possession of the leased premises in September, 2005.
6. The property at issue is a portion of that real property as described in the legal
description attached hereto as Exhibit "B" and incorporated by reference.
7. Plaintiff purchased the property referenced on Exhibit "B" on March 31, 2003 by
deed recorded at Book 256, Page 1697, with the Recorder of Deeds of Cumberland County.
8. Plaintiff avers that to its knowledge judgment is not being entered herein against a
natural person in connection with a residential lease.
9. Plaintiff avers that no party to the Commercial Lease has assigned any portion of
their interest in said Commercial Lease to any other person or entity.
10. Plaintiff avers that to its knowledge no judgment in ejectment has been entered
against Defendants with regard to the aforesaid Commercial Lease in any jurisdiction.
11. Defendants have defaulted under the terms of the Commercial Lease by failing
and refusing to make rent payments due under the Commercial Lease.
12. Notice was provided to Defendants of their default and the necessity of curing
said default.
13. Defendants failed to cure their default after notice.
WHEREFORE, Plaintiff requests judgment in ejectment be entered in its favor and
against Defendants together with costs and expenses of this action.
Respectfully submitted,
O' N, BARK SCHE
David A. Banc, Esquire
I.D. 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
dab.dit/corporate/gdw/ejectmentcomplaint.pld
~~
~~
!~ -V
~~~
COMMERCIAL LEASE
THIS LEASE entered into this 1st day of September, 2005, by and between
GDW, LLC, of Mystic, New London, Connecticut, (Landlord) and Warren Scott and Richazd
Butler, of Newville, Pennsylvania, (Tenant).
WITNESSETH: Landlord hereby leases to Tenant and Tenant leases ;from
Landlord, for the term and upon the teems and conditions hereinafter set forth, a portion of the
premises known as 34 North Corporation Street, Suite 2, Newville, Pennsylvania, together with
the buildings and other improvements constructed thereon as hereinafter provided, and together
with the right to use the parking spaces adjacent to the building, adjoining driveway, sidewalks
and means of ingress and egress.
SAID lease shall contain the following terms, conditions and restrictions;
1. LEASED PREMISES. The leased premises shall include a portion of the
building above described, being suite number 2 as further noted on the attached drawing which is
incorporated herein.
°' 2• 'T'ERM. This lease shall extend for a term of five (5) years, Said term to
begin the 1st day of September, 2005 and to end the 31 st day of August, 2010. Said term to be
automatically renewable for a five (5) yeaz term thereafter on the anniversary date. Should either
party intend to not renew the lease, such party shall make written notification to the other party at
Least ninety (90) days prior to the expiration of the then current term.
3• RENTAL. The rental for the first and second years hereof, shall be One
Thousand One Hundred Sixty Five and 00/100 Dollars, ($1,165.00). For every year thereafter,
EXHIBIT "A"
02 06 04:12p GDW LLC
860 536-8250 p.5
the yearly rent shall increase by three percent {3%). First payment due the 1st day of September,
2005 and thereafter on the 1st day of every month. Tenant shall also at the execution of this
Commercial Lease provide to Landlord a security deposit in the amount of One Thousand One
Hundred Sixty Five and 00/100 Dollars ($1,165.00). Tenant shall not be entitled to any interest
on this amount deposited with Laadiord. At the conclusion of the lease team Landlord shall
refund the security deposit to Tenant less any costs and expenses incurred by Landlord to repair
the premises.
'I• USE. The premises may be used for the operation of a beauty and tanning
salon known as Your Hair Station or otherwise. The premises may be used for any other lawful
Purpose not in conflict with municipal zoning regulations which will make void or voidable any
insurance on the leased premises. '
5• UTILITIES. Tenant shall pay all utility charges including but not Iimited
to heat, air conditioning, water and sewer, and electric which shall be separately metered for the
azea leased to Tenant. Tenant shall be responsble for removal of snow from sidewalk and
Landlord shall be responsible for snow removal from the parking area, Tenant shall be
responsible for burglaz alarm maintenance and Landlord shall be responsible for fire and smoke
alarm maintenance. The parties recognize and agree that the burglar, Sre and smoke alarms are
all provided under one contract with ADT. Landlord sha1I submit invoices received from ADT
(or another service provider) upon receipt and Tenant shall remit to Landlord the dollar amount
charged for the burglar alarm within ten (10) days of receipt of the invoice from Landlord.
04:12p GDW LLC
860 536-8250
p.6
6• TA~'~ES. Landlord shall be Tesponsible for the payment of all real estate
taxes levied on the premises.
~• INSURANCE. Tenant shall, at ail times during the term of this Lease and
any extensions hereof a) purchase and maintain Public Liability insurance, including bodily
~.lm'Y and property damage coverage of not less than $1,000,000.00 per occurrence and b)
purchase and maintain inventory and equipment coverage of not less than 100% of replacement
cost of alt inventory on the leased premises.
Landlord shall be included as an additional insured, as their interest may appear,
on the public liability insurance policy secured by Tenant.
Proof of all insurances as regwired hereunder shall be delivered to Landlord as
requested from time to time.
8. SIGNS. Tenant shall have the right to place such signs as aze usual and
incidental to~Tenant's business, provided, however, such external signs must conform with ail
applicable zoning or sign regulations. Further, they must be maintained in a manner acceptable
to Landlord. All costs associated with approval of signage shall be born by Tenant. Landlord
will provide for sign on top of the building above business and lighted sign on street.
9• MAINTENANCE. Landlord agrees to be responsible for all exterior
maintenance of the building and surface of the parking areas, sidewalks and driveways, as well
as the structural soundness of the building, and all underground gas, water and sewer pipes.
Landlord shall also maintain at its expense, exterior lighting and Lawn and shrubbery located on
3
04:12p GDW LLC
860 536-8250
p.7
the premises. Tenant shall be responsible for interior maintenance of the demised premises and
shall retsYrn the premises to Landlord at the expiration of the team hereof in the same condition as
at the commencement of the lease term, ordinary wear and tear alone excepted. Landlord shall
be responsible for all repairs and replacement, as necessary, for all mechanical elements
including heating, air conditioning, lighting and plumbing. All repairs and replacements shall,
upon termination of the lease, become the sole property of Landlord.
10. PARKING. Parking spaces in the adjoining parking azea excepting those
spaces immediately adjacent to the East wall of the building may be used by Tenant's customers
as needed and if they are available. Landlord reserves the right to lease parking spaces in the
adjoining parking area as Landlord desires and for Landlord's business in which case, Tenant
and Tenant's customers or employees will not be permitted to use the adjoining parking area
Tenant may not store (defined as having in place for more than atwenty-four hour period)
egiupment, materials or vehicles in the parking spaces adjacent to the building.
11. AL'I'ERATTONS AND TRADE AND OTHER FIXTURES. Tenant shall
not make any alterations involving structural changes without securing Landlord's written
consent. Tenant may install or cause to be installed such equipment and trade and other fixtures
as are reasonable and necessary for the operation of its business. Any equipm~k trade and
other fixtures which become attached to the property shall become property of the Landlord.
Approved structiu~l changes shall become the property of Landlord upon expiration or
termination of this lease. Tenant shall repair any damage to the leased premises by the
04:13p GDW LLC
860 536-8250 p.8
installation or removal of such alterations, equipment and fixtures.
12. CASUALTY DAMAGE. If the demised premises shall be partially
damaged by fire or other cause, the damages shall be repaired by and at the expense of Landlord.
Tf the demised premises or the building of which they aze a part are so damaged that
Landlord shall decide to demolish it and/or rebuild it, Landlord must, within thirty (30) days
after such fire or other cause, give Tenant a notice in writing of such decision, and thereupon the
term of this lease shall expire by lapse of time upon the thirtieth (30th) day after such notice is
given, and Tenant shall vacate the demised premises and surrender the same to Landlord.
This lease shall not be deemed terminated by reason of total or partial destruction
except as herein provided and Tenant hereby expressly waives any statutory provisions
concerning such rights, if any.
If the demised premises shall be partially damaged by fire, the elements or other
casualty but not so as to be rendered untenantable, the rent payable hereunder shall be paid
proportionate to that portion of the demised premises which remains tenantable and said
proportionate rent payments shall continue until such time as the premises shall be fully restored.
If the demised premises is damaged to the extent that Tenant cannot reasonably conduct its usual
business, rent payments shall abate during the period the demised premises remains in such
condition. In case the demised premises is completely destroyed by fire, the elements or other
casualty, or so damaged that it will or does remain untenantable for conducting Tenant's usual
business, Tenant may give Landlord written notice of his intention to then cancel this agreement
04~13p GDW LLC
860 536-8250 p.9
in its entirety or, alternatively, rent payable hereunder shall abate until the premises is restored
such that Tenant can resume conducting its business in the premises.
13. LIABILITY. The Tenant agrees to be responsible for any damage to the
property of the Landlord which may result from any use of the demised premises, or any act
done thereon by the Tenant or any person coming or being thereon by the license of the Tenant,
express or implied, and also to save the Landlord harmless from any liability to any person, for
damage to person or property, resulting from any such causes, and to protect such liability with
Public Liability Insurance and to furnish Landlord a certificate issued by the insurance carrier
showing such insurance in force and with Landlord covered thereby with limitations of at least
$1,000,000.00 personal injury and/or death and/or property damage. Tenant agrees to replace all
glass broken, damaged or destroyed in any manner whatsoever, the Tenant assuming all
responsibility for the glass in the premises herein demised, and to cause such liability to be
protected.~by plate glass insurance at Tenant's expense and further to deposit such plate glass
insurance policy or certificate showing such insurance in force with Landlord during the term of
this lease. Tenant agrees, at Tenant's expense, to keep all plumbing and heating lines from the
point of entrance to demised premises to the point of actual use tight and &ee from leakage and
stoppage at all times. If Tenant shall enter the demised premises prior to the term hereof, Tenant
shall be liable as herein set out, and such occupancy shall be upon all the terms and conditions
hereof except that rent shall be due at the time set forth in Paragraph 1 hereof. Such prior
occupancy by Tenant shall be at its own risk.
6
tVov 02 06 04:13p GDW LLC
860 536-8250 p. 10
14. COMPLIANCE WITH LAWS. Tenant will promptly comply with all
applicable aad valid laws, ordinances and regulations of Federal, State, County, Municipal or
other Iawful authority Pertaining to the use and occupancy of the leased premises, In the event
anY repairs or modifications may be determined as necessary under the Americans with
Disabilities Act, Tenant and Landlord will undertake to have made the modifications and the
modifications shall become the property of Landlord. All repairs or modification needed to
comply 'with current or future codes, Iaws or ordinances pertaining to the exterior of the properly
and building, shall be the responsibility of the Landlord.
e
Nov 02 06 04:13p GDW LLC
860 536-8250 p.ll
l5
BANKRUPTCY. Should Tenant make an assignment for benefit of
creditors, or. be adjudicated bankrupt, such action shall constitute a breach of this lease for which
Landlord, at its opinion, may terminate all rights of Tenant or its successors in interest under this
lease.
16. EMINENT DOMAIN, If all of the leased premises and common areas are
taken under the power of eminent domain or conveyed under threat of condemnation
proceedings, or if only a part of such premises or common areas is so taken or conveyed and
Tenant shall determine that the remainder is inadequate or unsatisfactory for its purposes, which
determination shall not be arbitrarily or capriciously made, then, in either event, this lease shall
terminate effective as of the date Tenant is required to give up the right to occupy or use any part
of the leased premises or common areas. The termination of this lease as above provided shall
not operate to deprive Tenant of the right to make claim against the condemning authority for
any damages suffered by Tenant, but Tenant shall have no right to make any claim against
Landlord because of such termination. If this lease is not terminated as above provided,
Landlord and Tenant shall agree upon an equitable reduction of the rental. If the parties fail to
agree upon such reduction within 60 days from the date of the final award or payment for the
part of the leased premises so taken or conveyed, Landlord and Tenant shall each choose one
arbitrator and the two arbitrators so chosen shall choose a third arbitrator. The decision of any
two of the arbitrators as to the rental reduction, if any, shall be binding on Tenant and Landlord
and any expense of the arbitration sha11 be divided equally between Tenant and Landlord.
Hov 02 06 04:13p GDW l_LC
l7. DEFAULT.
860 536-8250 p. 12
A. In the event of any of the following occurrences of °enforceable
default", Landlord shall be entitled to pursue one or more of the remedies set forth herein:
I) Non-payment of rent for a period often (I 0) days following
the due date, provided Landlord shall have given Tenant
written notice of said non-payment and an additional fifteen
(IS) day opportunity to cure said default in payment.
2) Breach of any of the other covenants of this Iease provided
that Landlord shall have given Tenant written notice of
such breach and a period of thirty (30) days within which to
cure same.
3) The filing of a petition in bankruptcy, whether voluntary or
involuntary, against Tenant or Tenant's adjudication as
bankrupt or insolvent in any court.
4) The appointment of a receiver or trustee in bankruptcy for
Tenant.
5) The making of any assignment by Tenant for the benefit of
creditors.
B. Remedies.
I) Confession of Judgment.
a) Lessee hereby empowers any Prothonotary or
Attorney of any Court of Record to appear for
Lessee in any and all actions which maybe brought
to recover the rent due for the remainder of the
term; and/or to sign for Lessee an agreement for
entering in any competent court an Amicable
Action or Actions for the recovery of such rent, and
in said suits or in said Amicable Action or Actions
to Confess Judgment against Lessee for the rent
due, and for the rent for the remainder of the term,
06 04:14p GDW LLC
860 536-8250 p. 13
and for interest and costs, together with reasonable
attorney's fees; and Lessee hereby expressly waives
and releases ail errors and defects in entering such
judgment and further waives and releases all relief
from any and atl appraisement, stay or exemption
laws, now in force or hereafter to be passed, and
also waives the right of inquisition on any real
estate that may be levied upon to caIlect such rental.
b) Any Attorney of any Court of Record of the County
of Cumberland may, at the request of Lessor, and,
as the agent or the attorney of Lessee, sign an
agreement for entry in a competent court an
Amicable Action of Ejectment and confess
Judgment in Ejectment thereon for the said
premises to any teen, past or present, against
Lessee, and all persons claiming under Lessee,
without stay of execution, or appeal, and, for so
doing, this shall be a sufficient Waxrant; and,
thereupon, a Writ of Possession or such other writ
as may then be appropriate may immediately issue
on said Judgment, all errors and defects in entering
such Action and Judgment, or in the issuing of such
Writ, or in any proceeding thereon, or concerning
the same, being hereby expressly waived by Lessee,
and by any person or persons whatsoever claiming
through, by or under Lessee, and a copy of this
Lease, with any modifications thereof, being filed in
the said Action, it shall not be necessary to file the
original as a Warrant of Attorney, any law or Rule
of Court to the contrary notwithstanding.
2) At the option of Landlord, this Lease shall determine, and
become null and void, and Landlord may re-enter upon,
and repossess, the herein demised premises.
3) The exercise of any remedy or remedies provided herein,
by Landlord, shall not preclude Landlord's ex~sthg~
concurrently or successively, one or more other remedies
provided herein, or authorized bylaw.
io
04:14p GDW LLC
860 536-8250 p. 15
18. LANDLORD'S COVENS, Landlord covenants that it has good and
marketable title to the demised premises by and through a certain Installment Sales Agreement
and that the same is subject to no leases, tenancies, agreements, encumbrances, liens, restrictions
or defects in title affecting the demised premises or the rights granted Tenant in this lease; that
there are no restrictive covenants, zoning or other ordinances or regulations applicable to the
denused premises which will prevent Tenant from conducting their usual business.
19• QUIET ENJOYMENT. Tenant upon paying the rent and perforating the
covenants and agreements of this lease shall quietly have, hold and enjoy the demised premises
and all rights granted Tenant in this lease during the term thereof and extensions thereto, if any.
20• SUBORDINATION. Tenant hereby agrees that its leasehold interest
hereunder is subordinate to any mortgages or installment sales obligations now on, or hereafter
to be placed on, the prennises leased hereunder.
This Subordination Agreement shall beself-operative and no further instrument or
certificate of subordination shall be required from Tenant.
2I . NOTICES. Any notices required or permitted hereunder shall be in
writing and delivered either in person to the other party or the other party's authorized agent, or
by United States Certified Mail, Return Receipt Requested, postage fully prepaid, to the
addresses set forth hereinafter, or to such other address as either party may designate in writing
and deliver as herein provided.
Lariiilord: GDW, LLC
12
nov uz 06 04;14p GDW LLC
. 860 536-8250 p. 16
Tenant:
~. RECORDING. This lease agreement shall not be filed for public record
by any party hereto.
23. COMPLETE AGREEMENT. This lease contains a complete expression
of the agreement between the parties and there are no romises r
P , epreSentations or inducements
except such as are herein provided
24. NO'T'ICE OF VIOLATIONS. Landlord represents and warrants that it has
received no notices that the premises are in violations of any laws, ordinances, and/or re latio
relating to the ~~ thereof or of any violations of building codes or other la ~ ~
and/or ms's, ordmances
regulations.
This lease agreement shall inure to the benefit of and be binding upon the
parties hereto and their respective heirs, Iegal representatives, successors and assigns.
25. ASSIGNMENT AND S~LETTING. Tenant shall not have the right to
assign or sublease the whole or any part of the demised premises without the prior written
consent of Landlord.
13
Mov 02 06 04:14p GDW LLC
' 860 536-8250 p. 17
IN WITNESS WHEREOF, the undersigned parties have affixed their hands and
seals to this Lease Agreement the date first above written
WITNESS:
GDW, LLC
sy: ~7 ~; , n~~~~ (sue)
Title: (~~, ~; ~~
(Seal)
Tenant
Tenant (Seal)
]4
LEGAL DESCRIPTION
ALL that certain tract of land situate in the Borough of Newville, County of Cumberland and
State of Pennsylvania, bounded and limited as follows:
BEGINNING at a spike in the eastern curb line of Corporation Street at corner where southern
edge of Maryland Avenue as relocated by the Borough of Newville intersects the eastern curb
line of Corporation Street; thence along Maryland Avenue and lands now or formerly of
Newville Little League, Inc. North 71 degrees 30 minutes East 200.27 feet to an iron pin; thence
along lands now or formerly of Newville Little League, Inc. South 72 degrees East 98.00 feet to
an iron pin; thence along same South 35 degrees East 3.03 feet to an iron pin; thence over lands
of Grantors herein South 58 degrees 43 minutes West 247.25 feet to an iron pin in the eastern
curb line of Corporation Street (it being the intention of the Grantors herein that the southern
building line of bowling alley building presently located on the premises shall along its entire
length be parallel to the last-mentioned course); thence along the eastern curb line of Corporation
Street North 37 minutes 10 seconds West 122.19 feet to a spike in the eastern curb line of
Corporation Street at corner where southern edge of Maryland Avenue as relocated by the
Borough of Newville intersects the eastern curb line of Corporation Street, the place of
BEGINNING.
BEING the same premises which Roger A. Hoover, Charles L. Hoover and Shirley L. Hoover, by
Deed dated and recorded even date herewith, granted and conveyed unto GDW, LLC,
Mortgagors herein.
EXHIBIT "B"
z ~ _
~:
~ ~ ; W n ri"T'T
~ :,~~~
~~1 r3
~
p-- '~ $ ~
..-.. :s3
-<
o ~ g
`~
GDW, LLC,
v.
IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
WARREN SCOTT and
RICHARD BUTLER,
individually and d/b/a
Your Hair Station,
Defendants.
NO. ~ _ ~ g~ ~ ~~
CIVIL ACTION-LAW
CONFESSION OF JUDGMENT
CERTIFICATION OF ADDRESSES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
David A. Baric, Esquire, being duly sworn according to law, deposes and says that to the
best of his knowledge, information and belief, the addresses of the judgment creditor and the
judgment debtor in the above-captioned case are as follows:
Plaintiff:
GDW, LLC
15 Whitehall Pond
Mystic, Connecticut 06355
Defendants:
Warren Scott
Richard Butler
34 North Corporation Street, Suite 2
Newville, Pennsylv is 17241
David A. Baric, Esquire
SwornQto and subscri~b„ed~be~folre -m' e
this ~ u~day of ~i IAUAX,/-1~1 , 2006.
dab.dir/corporate/gdw/add ress. aff
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Jennifer S. Lindsay, Notary Public
Carlisle Boro, Cumberland County
MY Commission Expires Nov. 29, 2007
Member, Pennsylvania Association Of Notaries
na
~ ~
-
r r7
-ct ~-;
~
`
-
_;
-~.
- ~' ~ ~ rr
rt7
r--
' -~ ~
-~
` p -
~
i_
~
~.. ~cJ
~y
d
_
G:. t" v ..
_
! ~~
~~- ~ ,
Lr.~ ~
GDW, LLC,
Plaintiff,
v.
WARREN SCOTT and
RICHARD BUTLER,
individually and d/b/a
Your Hair Station,
Defendants.
IN THE COURT OF COMMON PLEAS OF
. CUMBERLAND COUNTY, PENNSYLVANIA
NO. Q~ _ 1og99
CIVIL ACTION-LAW
CONFESSION OF JUDGMENT
AFFIDAVIT OF COMMERCIAL TRANSACTION
I hereby certify that I am counsel for GDW, LLC, the Plaintiff herein, and hereby certify
that judgment is not being entered against natural persons in a consumer transaction.
Respectfully submitted,
' EN, BARIC & SCH R
David A. Baric, Esquire
I.D. 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
dab.dir/corporate/gdw/com mercialtransaction.a ff
N
O
..
~ t.j
~~LT'
- ~ ~
,
C ~
.a~ ~
r
~~,
=
~ i
i",
~^
!-= `- ~ .,a
o~)
. `__
~
~
_
~~
~:;
(~ ~ J f°I3
!V ~}
C.,;: ^G
i
GDW, LLC,
Plaintiff,
v.
WARREN SCOTT and
RICHARD BUTLER,
individually and d/b/a
Your Hair Station,
Defendants.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
CONFESSION OF JUDGMENT
NOTICE OF JUDGMENT PURSUANT TO Pa.R.C.P. 236
TO: Richard Butler
34 North Corporation Street, Suite 2
Newville, Pennsylvania 17241
Notice is hereby given to you of entry of a judgment against you in the above matter.
Pro`~Tion tary
Date: _ ~ _ ' ~, a~~
GDW, LLC, IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. ~(o - ~~9 ~ C~li~r
WARREN SCOTT and
RICHARD BUTLER,
individually and d/b/a
Your Hair Station,
Defendants.
CIVIL ACTION-LAW
CONFESSION OF JUDGMENT
NOTICE OF JUDGMENT PURSUANT TO Pa.R.C.P. 236
TO: Warren Scott
34 North Corporation Street, Suite 2
Newville, Pennsylvania 17241
Notice is hereby given to you of entry of a judgment against you in the above matter.
~' f
Prothonot
Date: ~4[~ .~0. ~
.. ~ 4
SHERIFF'S RETURN - REGULAR
CASE N0: 2006-06899 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GDW LLC
VS
SCOTT WARREN ET AL
I
says, the within NOTICE UNDER RULE 2958.1 was served upo'~
~(''(l'TT SA~RRRN TIRA V(ITTR NATR 4TATTnN the
ROBERT BITNER Sheriff or Deputy Sheriff f
Cumberland County,Pennsylvania, who being duly sworn accor 'ng to law,
DEFENDANT at 1200:00 HOURS, on the 15th day of Dece er 2006
at 34 N CORPORATION ST SUITE #2
NEWVILLE, PA 17241 by handing to I~
WARREN SCOTT
a true and attested copy of NOTICE UNDER RULE 2958.1 toge~ er with
and at the same time directing His attention to the contenll; thereof.
Sheriff's Costs: So Answers:
Docketing
Service 18.00
10.56
~ ~~,~
i~~~I*'
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
~ 3-~ 8.56 12/28/2006
,/a _316 ~ ~"~~ OBRIEN BARI C SCHERER
Sworn and Subscibed to By: l
.~~
before me
this
day ~
Deputy Sh
of A.D.
ri
•...~
.r.r
.:.r
..r..
..,r..
+.~
~ Y
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-06899 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GDW LLC
VS
SCOTT WARREN ET AL
JASON MORAL Sheriff or Deputy Sheriff f
Cumberland County,Pennsylvania, who being duly sworn acco ing to law,
says, the within NOTICE UNDER RULE 2958.1 was served upo
BUTLER RICHARD DBA YOUR HAIR STATION the
DEFENDANT at 1616:00 HOURS, on the 27th day of Dece
at 348 DOUBLING GAP ROAD
NEWVILLE, PA 17241 by handing to
RICHARD BUTLER
r 2006
a true and attested copy of NOTICE UNDER RULE 2958.1 toge~~er with
and at the same time directing His attention to the contenlc~ thereof.
Sheriff's Costs:
Docketing 6.00
Service 10.56
Postage .39
Surcharge 10.00
/ GbyS
//j3 /b 7
Sworn and Subscibed to
before me this day
of
So Answers:
~'f ~.`,~~7~,.r~~rrt~
R. Thomas Kline
12/28/2006
OBRIEN BARIC SCHERER
By : ~-~
ty Sherif:
A.D.
.rw
...,
.,rr
,.~
,~