Loading...
HomeMy WebLinkAbout95-04230 , i ~ o r.:f . ~ ~ .f. ~ f I <l ,.." ~ . .",,' " ~\, " 1-" en . ,. . ~ ) "t~ . ~ \\ ~~ ~\) ;.:.~ ....., '" (".:..::" f.o, ~.~ " ~ ('\ I.)., '- '1 ~\ ~~ ^lIV .lONOH.lO~:::'JttIc::J"'" "~~'~';g~' ~~i~~~;'" .5b'6l ,.........=ti't>....:~..,..,.... c..1'( . ~~ u :z; H . ~~ ~ '" IU - r.l E ~ H E-t ~ Q 3 Ji ~ 1II 'tl ~ :z; ~ . H tI.l ~ ~ ~ ~j~ H I'( c.. ~ ~~ gjClfl ~ '" ~ ~ j o I H ~s:: ~ ~ E-tO U ...:l811l ~ ~ ~ ~ U:Z; H.j.J U ~~8 !l'i,~ 8~1l ~ ~ ~ ~ CIl UIIl 'll4 ~;;: . '111 CIl <I > ~~Q U ~ ~~ IE ~. H OH r.l ~ :z; HO ~ , , . . '-, .. , , ~ GLEIM TECHNICAL INSTITUTE, INC. , . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff . . . . NO. 95- 4,)30 CIVIL TERM v. JASON D. POOLER and JUDITH B. POOLER, Defendants . . 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 the pleadings and Notice are served, 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 pleadings or for any other claim of 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 00 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. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 tf/%u ~ Wayne It. Shade, Esquire Supreme Court I.D. #15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNI! F. SHADI! AtsDmty at I.... Sl Wul l'omIrd SItttt Clrwlt. I'mn.yl....nia 17013 WAYNIl F. SIIADI! Atlomt)"ll.aw 5) Wrll Pomfrrt Stmt Carlidr. rn.nl)'lvania 170ll GLEIM TECHNICAL INSTITUTE, INC. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff v. NO. 95- CIVIL TERM JASON D. POOLER and JUDITH B. POOLER, Defendants COMPLAINT 1. Plaintiff is GLEIM TECHNICAL INSTITUTE, INC., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its main office and principal place of business at 475 Sherwood Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant JASON D. POOLER is an adult individual who resides at 215 Geary Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Defendant JUDITH B. POOLER is an adult individual who resides at 118 Yellow Breeches Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 4. On or about September 14, 1992, Defendants executed a Note in favor of Plaintiff and payable to Plaintiff at Carlisle, Pennsylvania, a copy of which is attached hereto as Exhibit "A" and incorporated herein by reference as though fully set forth. W^YfoIl! F. SI/^,m Attomty at I.... 5l Wnl rc.nrm Sllffl earlidt.I'rnnI)lvlnll 17011 5. since execution of the Note, Plaintiff has received payments on account reducing the principal balance due to $1,910.43 and paying the interest through November 15, 1994. 6. In spite of repeated demands of Plaintiff, Defendants have refused to make any further payments. WHEREFORE, Plaintiff demands judgment against Defendants in the amount of $1,910.43 plus costs, interest as set forth in the Note from November 15, 1994, and counsel fees in the amount of $1,500. ~ ~~ Wayne~hade, Esquire Supreme Court 1.0. #15712 53 West Pomf=et Street carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff -2- I, KAREN S. GLEIM, verify that I am the Business Manager of Gleim Technical Institute, Inc., that I make this verification on its behalf being authorized to do so and that the statements made in the foregoing complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904 relating to unsworn falsification to authorities. Date: August 4, 1995 d~,- ~.~ Karen S. Gle m WAVNI! F. SUAIlI! Attlml()' It taw Sl Wnl 1".lIhcl SU<<I l"111i,k. l'rnnl)'lvani.ll !7UB /, ,,,,,,,...0/ ... " RECEIVED AUG 2 8 1992 GTI NOTE SEPTEMBER 14, 1992 $ 2,425.00 FOR VALUE RECEIVED, the undcrslgncd promlscs to pay to the order of GLEIM TECHNICAL INSTITUTE, INC., at Carlisle, Cumberland County, Pennsylvania, or at any othcr place In thc Commonwcalth of Pennsylvania that any holder of this note may designate In writing, the sum of $ 2.425.00 ITwo-thousand-four-hundred-twentY-flve 00/1001Dollars with Interest at the rate of 8% per annum until fully paid. Carl Isle, Pennsylvania This Notc, togcther wi th al I interest duc thcreon, is duc and payable in 24(tw~!!.l.Y-fourJ_ monthly installments of $ 109.68 IOne- hundred-nine an(L~I..1.Q...0~__ Dollars commencing January 15. 1993. Maker shall have the right to prepay the principal of this Note in wholc or In part prior to its duc date without premium or pe~ally. I f this Note Is placed In the hands of an attorney for collection or Is collected by a suit 'or through bankruptcy, probate or either court proceedings, clther before or after maturity, there shall be paid to the holdcr of this Note attorney fees In the amount of $1;500.00, court costs a~d other expenses Incurred by the holder In enforcing the terms of this Note. Fal lure to pay any part of the principal or interest of this Note when due shall authorize the holder of this Note to declare as Immedia.tely due and payable, In addition to all obi Igations accrucd hereunder, the then unpaid principal and Interest and to exercise al I other rights and remedies either at law or in equity possessed by the holdcr of this Note. The makers, signers and endorsers of this Note severally waive demand, presentment, notice of dishonor, diligence In collection, and notice of protest. and agree to all extensions and partial payments before or after maturity, wi thDUt prejudice to the holder. EXHIBIT "A" . '. ". The maker of this Note authorizes any attorney-at-law to appoar before the Prothonotary of any Court of record of the CDmmonweal th of Pennsylvania or In any other CommDnwoalth or State In the Unltod States at anytime after this Note becomes due, whether by acceleration or otherwise, and to waive the issuing and service of process and confess a judgment In favor of the legal hDlder against any maker and endorser, for the amount of principal and Interest then appearing due on this Note, together with costs of suit and attorney fees aforesaid, and to release all heirs and waive aJ I right of appeal. Entry of judgment upon this Note by confession shal I not exhaust the authority for further entries of jUdgment In favor of any legal holder against any maker or endorser for the amount of principal and Interest then appearing due on this Note, together with costs of suit and attorney fees aforesaid. WARNING BY SIGNING THIS PAPER, YOU GIVE UP YOUR RIGHT TO NOTICE AND COURT TRIAL. I~ YOU 00 NOT PAY ON TIME, A COURT JUDGMENT MAY BE TAKEN AGAINST YOU WITHOUT YOUR PRIOR KNOWLEDGE; AND THE POWERS OF A COURT CAN BE USED TO COLLECT FROM YOU REGARDLESS OF ANY CLAIMS YOU ~AY HAVE AGAINST rHE CREDITOR, WHETHER FOR RETURNED GOODS, FAULTY GOODS, FAILURE TO COMPLY WITH THE AGREEMENT OH ANY OTHER CAUSE, IN WITNESS WHEREOF, the undersigned has hereunto set his hand and sea I the ~XWllXJSr.w/o{''fXilflKlO!~l(.lClOOtll1lWL 25th day of August. 1992. ~dArn _ .Jj., -I2rrr&,,,-- 5 nature ason D. PDoler ~ Judith B. 13. (In-tuJ Pooler -2- . GLEIM TECHNICAL INSTITUTE, INC. , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95-4230 CIVIL TERM v. JASON D. POOLER and JUDITH B. POOLER, Defendants PRAECIPE TO: Lawrence E. Welker, Prothonotary Please reinstate the Complaint in the above-captioned matter. Date: August 22, 1995 d!~/ /"".JZ6 wayne . Shade, Esquire Attorney for Plaintiff W^YNE F. SH^DE ^aomcy II ~ l3 Well PomIrd Slrtd C.rlidc. Pmluytvuli. 17013 SHERIPP'S RETURN - NOT POUND CASE NOI 1995-04230 P COMMONWEALTH OP PENNSYLVANIA I COUNTY OP CUMBERLAND GLEIM TECHNICAL INSTITUTE INC VS. POOLER JASON D ET AL R. Thomas Kline to law. says. that he made named defendant. to witl . Sheriff. who being duly sworn according diligent search and inquiry for the within POOLER JASON D but was unable to locate Him in her bailiwick. He therefore returns the COMPLAINT NOTICE NOT POUND . as to the within named defendant POOLER JASON D DEPENDANT MOVED AND LEPT NO FORWARDING ADDRESS WITH THE POST OFFICE. Sheriff's CoStSI Docketing Service Affidavit Surcharge 18.00 9.52 .00 2.00 $29.52 WAYNE I ,,-~,.0B/181 JI ----- J 'I ,,,- Sworn and subscribed to before me this ?,' ~ day of Q'<J'..r- 19 r,"; A. D. (~I'1""" G JlL~((""', d;p77 , , ~rothonotary SHERIFF'S RETURN - NOT FOUND CASE NO: 1995-04230 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GLEIM TECHNICAL INSTITUTE INC VS. POOLER JASON D ET AL R, Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made diligent search and inquiry for the within named defendant, to wit: POOLER JUDITH B but was unable to locate Her the COMPLAINT NOTICE NOT FOUND , as to the within named defendant POOLER JUDITH B ABOVE ADDRESS IS LOCATED IN YORK COUNTY. in her bailiwick. He therefore returns Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 2.00 68.00 ~.<. WAYNE S 08/18/1 Sworn and subscribed to before me this 3r,u". day ofQ"j'ur 19 '1{ A.D. C)1'~ (1. l,)-\~;i'(i .C"t'j' I'rothono ary' GLEIM TECHNICAL INSTITUTE, INC. , .Plaintiff :. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 95- .y'.;>3Cl CIVIL TERM '.. JASON D. POOLER and JUDITH B. POOLER, Defendants 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 the pleadings and Notice are served, 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 pleadings or for any other claim of 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland county Courthouse Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 d!tau< ~ Wayne~. Shade, Esquire Supreme Court I.D. #15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNP. F. SHADD AtIorDq II Law 53 Well .....,'" sum Carlhk, I'alluylv.... 17013 . ..... ,. -\J.' ';;' ,-'.....~r.:.c"i"J f ,- ! . ...~ r..:. -'~ {' r,', ,i'l. ~ .'...~. ..~ .. . i."....- ... .\..., - A . .. l I -",' ''It:l s;,~ r:1V I~tju 1_, t ....l'n"J"" \'J,'tf~'\;';U',. \ ,'!-~.l ..;. \ 'J I, ." ~ .f - 1 f' ..1......., ....___ , 1.,',4" 'J' 31 ~,'"'''''' .. '11'11~ rA'l 0 ~.l.' \.\.. .1, "" . .. ,,,,r,. /. \~~ lhi5..._S.Y~~_d<ly oLl ~~i': 7"/ -k14t,u!-....- It'. U"''-> "'r (/ Pmliwnl1l!,t'j GLEIM TECHNICAL INSTITUTE, INC., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . " . . .Plaintiff v. NO. 95- CIVIL TERM JASON D. POOLER and JUDITH B. POOLER, Defendants COMPLAINT 1. Plaintiff is GLEIM TECHNICAL INSTITUTE, INC., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its main office and principal place of business at 475 Sherwood Drive, Carlisle, Cumberland County, pennsylvania 17013. 2. Defendant JASON D. POOLER is an adult individual who resides at 215 Geary Avenue, New Cumberland, Cumberland county, Pennsylvania 17070. 3. Defendant JUDITH B. POOLER is an adult individual who resides at 118 Yellow Breeches Drive, camp Hill, Cumberland county, Pennsylvania 17011. 4. On or about September 14, 1992, Defendants executed a Note in favor of Plaintiff and payable to Plaintiff at Carlisle, Pennsylvania, a copy of which is attached hereto as Exhibit "A" and incorporated herein by reference as though fully set forth. WAYNI! F. SHADE A_"u.. nw..._..._ Cutisk. ......,IY.... .7013 6. 5. . Since execution of the Note, plaintiff has received payments on account reducing the principal balance due to $1,910.43 and paying the interest through November 15, 1994. In spite of repeated demands of plaintiff, Defendants have refused to make any further payments. WHEREFORE, Plaintiff demands judgment against Defendants in the amount of $1,910.~3 plus costs, interest as set forth in the Note from November 15, 1994, and counsel fees in the amount of $1,500. ~ ;::-~ Wayne~hade, Esquire supreme Court I.D. #15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYIII! F. SHADe A1IonIc1 ac Law S3W",Pomf"'_ CuIWe. _Ivlllla 1701J -2- I, KAREN S. GLEIM, verify .that I am the Business Manager of Gleim Technical Institute, Inc." that I make this verification on its behalf being authorized to do so and that the statements made in the foregoing complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904 relating to unsworn falsification to authorities. Date: August 4, 1995 .. ~~~~, Karen S. Gl~ m' ,..,t. --. WAYNe F. SHADe Aaomey at Law l3 W... _.... SIml Cadiale. PmnJytvania .7013 , -. '. I. I U......., ... RECEIVED hUG 2 8 1992 GTI . NOTE SEPTEMBER 14, 1992 $ 2,425.00 FOR VALUE RECEIVED, the undcrslgncd promises to pay to thc order of GLEIM TECHNICAL INSTITUTE, INC., at Carl Isle, Cumberland County, Pennsylvania, or at any othcr place In thc Commonwcalth of Pennsylvania that any holder of this note may designate In writing, the sum of S 2,425.00 lTwo-thousand-four-hundred-twentv-flve 00/1001Dollars wi th Intercst at thc rate of 8% per annum unt II fully pa I d. Carllslc, Pennsylvania ,. This Note, together with all intcrest duc thereon, Is duc and payable In 24(tw~!l!'y-fourL monthly Installmcnts of $ 109.68 10ne- hundred-nine and_~I..1.Q..Q_ Dollars commcnclng January 15. 1993. Maker shall have t.hc right to prcpay thc principal of this Note In wholc or In part prior to Its due date without premium or pe~alty. I f this Note Is placed In thc hands of an attorney for collection or is collected bya suit ~r through bankruptcy,. probati or tither court proccedlngs, either before or'after maturity, there' shal I' . be paid to the holdcr of this Ncte 3ttorne~ fces In the amount of . $1;500.00, court costs a~d other expenses Incurred by the holder I~ enforcing the terms of this Note.' , Failure to pay any part of the principal Dr Interest of this Note when' due shal I authorize the holdcr of this Note to dcclarc as Immcdla1ely due and payab Ie, I n add I t Ion tD a II ob II ga II ons accrued hereunder, the then unpaid principal and intcrcst and to cxercisc all other rights and remedies either at law or In equity possessed by the holdcr of this Note. The makcrs, signers and endorscrs of this Note severally waive demand, presentment, notice of dlshDnor, diligence In cDllection, and not Icc of protest, and agree to a II cxtenslons and part I a I payments befDre or after maturity, without prejudice to the holdcr. EXHIBIT "A" I' . ". " The maker of this Note authorizes any attorney-at-law to appear before the Prothonotary of any Court of record of the Commonwealth of Pennsylvania or In any other Commonwealth or State In the United States at anytime after this Note becomes due, whether by acceleratlDn ~'or otherwise, and to waive the Issuing and service of process and confess a judgment In favor of tile legal holder against any maker and endorser, for the amount of principal and Interest then appearing due on this Note, together with costs of suit and attorney fees aforesaid, and to release all heirs and waive all right of appeal. Entry of judgment upon this Note by confession shall not exhaust the authority for further entries of JUdgment In favor of any legal holder against any maker or endorser for the amount of principal and Interest then appearing due on this Note, together with costs of suit and attorney fees aforesaid. WARNING BY SIGNING THIS PAPER, YOU GIVE UP YOUR RIGHT TO NO~ICE AND COURT TRIAL. IF YOU DO NOr PAY ON' TIME, A COURT JUDGMENT MAY BE TAKEN AGAINST YOU WITHOUT YOUR PRIOR KNOWLgDGE; AND THE POWERS OF A COURT CAN BE USED. TO COLLECT FROM YOU'REGARDLESS OF ANY CLAIMS YOU ~AY HAVE , AGAINST THE CREDITOR, WHETHER FOR RETURNED GOODS, FAULTY GOODS, FAILURE TO COMPLY WITH THE AGREEMENT OH ANY OTHER CAU5E. IN WITNESS WHEREOF, the undersigned has hereunto set his hand and seal the ~~l!XJSr.~~. 25th day of August. 1992. . ~LfAn _ {j., -Rro-&~ S nature ason D. Pooler S~ fj. IJ~ Judith B. Pooler -2- .' .' "e'. C ^ . AUG. '1 , .' .oJ ~ tnl'u f3a ~ li'W GLEIM TECHNICAL INSTITUTE, INC. , .Plaintiff :. IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 95- J/~3(J CIVIL TERM . JASON D. POOLER and JUDITH B. POOLER, Defendants 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 the pleadings and Notice are served, 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 pleadings or for any other claim of relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THJS 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. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 dI~ ~_ Wayne It. Shade, Esquire Supreme Court 1.0. #15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYIlII F. SlWlE A.....,........ l3W..._"'_ CuIilIe. I'ftloIJIvIllia 17013 TRUE COpy FROM RECORO I i1T8'>lifOlJny whoreol, I here unto sat rrrt hand ,'11.1 lhe seal 01 said Cll\Jrt ~ Caf1tste, ~. This ::;"1/1 day of U . 19" " "t. ~_.- .... GLEIM TECHNICAL INSTITUTE, INC. , . " . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW .Plaintiff v. NO. 95- CIVIL TERM . . JASON D. POOLER and JUDITH B. POOLER, Defendants . . . . COMPLAINT 1. Plaintiff is GLEIM TECHNICAL INSTITUTE, INC., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its main office and principal place of business at 475 Sherwood Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant JASON D. POOLER is an adult individual who resides at 215 Geary Avenue, New Cumberland, Cumberland county, Pennsylvania 17070. 3. Defendant JUDITH B. POOLER is an adult individual who resides at 118 Yellow Breeches Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 4. On or about September 14, 1992, Defendants executed a Note in favor of Plaintiff and payable to Plaintiff at Carlisle, Pennsylvania, a copy of which is attached hereto as Exhibit "A" and incorporated herein by reference as though fully set forth. WAYNP. F. SHADE A.....,...Uw 51 W... PomI'''' sum CartWc. Peml)'tvania nOIl .5. . Since execution of the Note, Plaintiff has received payments on account reducing the principal balance due to $1,910.43 and paying the interest through November 15, 1994. '.. , 6. In spite of repeated demands of Plaintiff, Defendants have refused to make any further payments. WHEREFORE, Plaintiff demands judgment against Defendants in the amount of $1,910;43 plus costs, interest as set forth in the Note from November 15, 1994, and counsel fees in the amount of $1,500. ~ ~~ Wayne~hade, Esquire supreme Court I.D. #15712 53 West Pomfret street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADC Aaomey at law lIWeII_"'_ CarIWc, """'honla 17013 -2- '.. W^YNE F. SH^DE ADomcy II Law 53 Wut Porufm Sttetl CalUak, ~.ylvania 17013 I, KAREN S. GLEIM, verify.that I am the Business Manager of Gleim Technical Institute, Inc." that I make this verification on its behalf being authorized to do so and that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904 relating to unsworn falsification to authorities. Date: August 4, 1995 ~~~q, Karen S. Gl6 ~ .-Jl- '. I.......... . /, RECEIVED hUG 2 8 1992 GTI . NOTE SEPTEMBER 14, 1992 $ 2,425.00 Carl Isle, Pennsylvania " FOR VALUE RECEIVED, the underslg~ed promises to pay to the Drder of GLEIM TECHNICAL INSTITUTE, INC., at Carl Isle, Cumberland County, Pennsylvania, or at any other place In the Commonwealth of Pennsylvania that any holder of this note may designate In writing, the sum of $ 2.425.00 (Two-thousand-four-hundred-twenty-flve 00/1001Dollars wi th Interest at the rate of 8% per annum unt II fully paid. ,. This Note, together with all Interest due thereon, is due and payable In 24(twe!l!..i'-fourL monthly Installments of $ 109.68 (One- hundred-nine an(Lgl..1.Q..Q~__ Dollars commencing January 15, 1993. Maker shall have t.he right to prepay the principal of this Note In whole or In part prior to Its due date without premium or pe~alty. If this Note Is placed. In the hands of an attorney for . collection or Is collected by'a suit 'or through bankruptcy, probate or tither court proceedings, either before or'after maturity, there' shal I' be paid to the holder of this Note attorney fees in the amount of . $1;500.00, court costs a~d other expenses Incurred by the hDlder I~ enforcing the 1erms of this Note.' . Failure to pay any part of the principal or Interest of this Note when due shall authorize the holder of this Note to declare as Immedia.tely due and payable, In addition to all obligations accrued hereunder, the then unpaid principal and Interest and to exercise all other rights and remedies either at law or In equity possessed by the holder of this Note. The makers, signers and endorsers of this Note severally waive demand, presentment, notice of dlshDnor, diligence In collection, and notice of prDtest, and agree to al I extensions and partial payments before or after maturity, without prejudice to the holder. . . EXHIBIT "A" .' . '. . " ., The maker of this Note authorizes any attorney-at-law to appear befDre the Prothonotary of any Court of record of the Commonwealth of Pennsylvania or In any other Commonwealth or State In the United States at anytime after this Note becomes due, whether by acceleratlDn ~'or otherwise, and to waive the Issuing and service of process and confess a judgment In favor of the legal holder against any maker and endorser, fDr the amount of principal and Interest then appearing due on this Note, together with costs of suit and attorney fees aforesaid, and to release all heirs and waive all right of appeal, Entry of JUdgment upon this Note by confession shall not exhaust the author Ity for further entries of Judgment In favor of any legal holder against any maker or endorser fDr the amount of principal and Interest then appearing due on this Note, together with costs of suit and attorney fees aforesaid. WARNING BY SIGNING THIS PAPER, YOU GIVE UP YOUR RIGHT TO NO~ICE AND COURT TRIAL. IF YOU DO NOr PAY ON' TIME, A COURT JUDGMENT MAY BE TAKEN AGAINST YOU WITHOUT YOUR PRIOR KNOWLeDGEj AND THE POWERS OFA COURT CAN BE USED TO COLLECT rROM YOU'REGARDLESS OF ANY CLAIMS YOU ~AY HAVE . AGAINST rHE CREDITOR, WHETHER FOR RETURNED GOODS, FAULTY GOODS, FAILURE TO COMPLY WITH THE AGREEMENT OR ANY OTHER CAU5E. IN WITNESS WHEREOF, the undersigned has hereunto set his hand and sea I the ~~ 25th day of August, 1992. ~LiAn1 _ fj., -Bnr&'-.- S nature ason D. Pooler S~ 16_ {J~ Jud I t h B. Poo Ie r -2- .' OF'" ~U~ ' '1" J,' - J \'\ ~?!fl) \~ :-.8 ~: ~.-. ~::.~."" f'" SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1995-04~30 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GLEIM TECHNICAL INSTITUTE INC VS. POOLER JASON D ET AL R. Thomas Kline , Sheriff. who being duly sworn according and inquiry for the within to law, says, that he made a diligent search named defendant, to wit: POOLER JUDITH B but was unable to locate Her in his bailiwick. He therefore County, Pennsylvania. deputized the sheriff of YORK to serve the within COMPLAINT On September 15th. 1995 , this office was in receipt of the attached return from YORK County, Pennsylvania. Sheriff's Costs: Docketing Out of County Surcharge YORK COONTY So answers: 18.00 9.00 2.00 16.00 $45.00 WAYNE SHADE 09/15/1995 / " ~ . ._-".~..1;" ./ ( . /'. R. Thomas K11ne, Sher111 Sworn and subscribed ~o before me this .I,.~~ day of .};"r.:,..i....... , 19 'i') A. D. ~k.. C. )lkLi..... ~T - Plothonotary 7 ADDITIONAL COMMENTS: Spoke with Tanya from the York County Sheriff's Dept. She advised that Deputies learned that defendant's son lives at within address. He stated defendant moved approximately two years ago, but does not know where. KENNETH L. MARKEL SHERIFF WALLIS W. RHINE REAL ESTATE DEPUTY EDWARD C. ROBERTS SOUCITOR SCOTT E. SHEWELL CHIEF DEPUTY GLEIM TEX:IlNICAL INSTITUTE INC'. IN TIlE COURT OF CGlMOM PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 95-4230 JASON D. POOLER & JUDITH B. POOLER SERVE: JUDITH B. POOLER AFFIDAVIT OF SERVICE I, Kenneth L. Markel, Sheriff of the County of York, Conmonwealth of Pennsylvania, after diligent search and inquiry as to the defendant, Judith B. Pooler, the within named defendant, do hereby return, Notice & Corrplaint, Nor FOUND in York County. Sheriff's Costs $16.00 So Answers, SWorn and subscribed to before me this 13th day of September 1995 'X,;>,,<,,~~~~,~.%~ KENNETH L. MARKEL SHERIFF COUNTY OF YoRk NOTARIAL SEAL Wallis W Rhine, NOla", Publle York, YO~k County, Pennlvlvlnil Mv Comm'ss,on E.p"as. March 25. t 999 "/'1, '-- I -. c ' . c ., I nEt OUrT OT .::mmO:1 ., I - .=-r:: , ".-- . - '-l ., or \..:..Jr.~~:~:~'1=:1.. ......:;L::-;~.y, P'S:1r:~yl"::r:i :: Gleim Technical Insitute Inc. 'is. Judith B. Pooler ~o. 95-4230 .~ivil Term .~ ---, ..~ ; .., ~ow. Auqust 25, 1995 ,. ' ~9---. !. S:~..z:~ 0: c~rnZ?..!..A.'fD COt..~TY. ?o\-. CO h=-~ li..::u= ::: Sc.:::.E oi York UU::t)' :0 :::::".1:.: :is ',V:!:, =:s :..~u=:cu =:!:1r _...l_ ~t :::: ~ ::0. :=...:k oi :.::: ?!.1!:::::i'. r_ ~~ V/ rtJ-~'~ff~.(. ift~ SlIe..~ =t C::::1ler'..u:d C.U::17. :':1. . .4.Sdavit or Sem~ So =we:, :;1-....:., oi CoWltT. ?:L. == =:s _ Q.y oi l~_ CO:u.;) SZRv"IQ: ~au:.~.G:;:: .~:wA"y'TL oS Swcr: ~d s::i:sc:-:i:d be:crc s r_ --.. ; , \ \ \ \ \ '. . TO VOU ARE H~REBY HOnFIED TO FILE A WRITTEH RESPOHSE TO THE ENCLOSED WITHIH TWEHTY I'.' OAVB FROU SERVICE HEREOF OR A JUDGMENT &,lAy BE ENTERED AGAINST YOU. BY WAVNEF. SHADE ATTORHEV AnoRNBY AT LAW 53 WEST PO"FRET STREET CARLISU!.I'EHHSYLVANIA 17013 . WE DO HEREBY CERTIFY THAT THE WITHIN IS A TRUE AND CORRECT COpy OF THE ORIOINAL FILED IN THIS ACntl~ TX ( BY . 'H'-'1r__ i~.L ( ATTORNFt r .~ .-- .... . GLEIM TECHNICAL INSTITUTE, INC. , :" IN THI:: COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW " , .Plaintiff t;'i v. NO. 95- tI ;)JeJ CIVIL TERM . . ".. ., JASON D. POOLER and JUDITH B. POOLER, Defendants . . .... 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 the pleadings and Notice are served, 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 pleadings or for any other claim of 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland county Courthouse Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 WAYIlB F. SHADE A_ II Law SJw.............- CItIiIIo, \'amI7(Y1llll 17013 TRUE CO~';'':'' i;~:('\.: ~;CC.oFi) I:, T:l":IIOl\J!',' '.7".......;. 1",,1' umu st<f iii'! 1~1i1l1 . , I.... .~,," c.', " '.~ 'J": ~l c..u11MIl, I"i. . .., ,'~ .. .." . Gr o .,..' "'1 _'0 I~ ,,5._..~ ,"\"')1 \,.1 .V:.__ !,.., 1:1__... _____.~~v,a... uafH<,--- .,o~1-' ;l~"h'."otl!oy dlraw ~_ Wayne It. Shade, Esquire supreme Court I.D. #15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYIlB F. SHADE A_It Law S3W.............- Culiale, \'amI7(Y1llll 17013 GLEIM TECHNICAL INSTITUTE, INC. , ,Plaintiff " :" IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 95- CIVIL TERM . . JASON D. POOLER and JUDITH B. POOLER, Defendants .. COMPLAINT 1. Plaintiff is GLEIM TECHNICAL INSTITUTE, INC., a corporation organized and existing under the laws of the Commonwealth of pennsylvania, with its main office and principal place of business at 475 Sherwood Drive, Carlisle, Cumberland County, pennsylvania 17013. 2. Defendant JASON D. POOLER is an adult individual who resides at 215 Geary Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Defendant JUDITH B. POOLER is an adult individual who resides at 118 Yellow Breeches Drive, Camp Hill, Cumberland county, Pennsylvania 17011. 4. On or about September 14, 1992, Defendants executed a Note in favor of Plaintiff and payable to Plaintiff at Carlisle, Pennsylvania, a copy of which is attached hereto as Exhibit "A" and incorporated herein by reference as though fully set forth. ca..' If:. ". <.' WAYIlB F. SHADE A__lo" S3W............._ CItIiIIo, \'amI7(Y1llll 17013 ,5. .. Since execution of the Note, Plaintiff has received payments on account reducing the principal balance due to $1,910.43 and paying the interest through November 15, 1994. 6. .. In spite of repeated demands of Plaintiff, Defendants have refused to make any further payments. WHEREFORE, Plaintiff demands judgment against Defendants in the amount of $1,910.~3 plus costs, interest as set forth in the Note from November 15, 1994, and counsel fees in the amount of $1,500. ~ ;:~ Wayne~hade, Esquire Supreme Court I.D. #15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff -2- ...._~ ' ...... ~;" ~.' I, KAREN S. GLEIM, verify ,~hat I am the Business Manager of Gleim Technical Institute, Inc.,. ,that I make this verification on its behalf being authorized to do so and that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904relating to unsworn falsification to authorities. Date: August 4, 1995 .. d.- A~~. . Karen S. Gl~t:.. ,..,t. " WAYIlB F. SHADE ^_ II Law 51W............._ CItIiIIo, \'amI7lvlllll 17011 /, '; , v... _" 0' .' '. RECEIVED AUG 2 8 1992 GTI .' NOTE SEPTEMBER 14. 1992 Carlisle, Pennsylvania $ 2,425.00 " ,', FOR VALUE RECEIVED, the underslgl}ed promises to pay to the order ot GLEIM TECHNICAL INSTITUTE, INC., at Carlisle, Cumberland County, Pennsylvania, or at any other place In the Commonwealth ot Pennsylvania that any holder of this note may designate In writing, the sum of S 2.425.00 ITwo-thousand-four-hundred-twentv-flve 00/1001Dollars wi th Interest at the rate of ~% per annum unt II fully paid. .' This Note, together wi th all Interest due thereon, 15 due and payable in 24(tw~!lty-fourL monthly installments of $ 109.68 10ne- hundred-nine and 681..UL~_ Dollars commencing Januarv 15. 1993. Maker shal I have ~he right to prepay the principal of this Note I n wh 0 I e 0 r I n par t p r lor t 0 its due d ate wit h 0 u t p r em I um 0 r p e ~ a I t Y . It this Note Is placed, in the hands of an attorney for , collect Ion or Is cOllec,ted by 'a sui t 'or through bankruptcy, probate or other court proceedings, el ther before or 'after maturl ty, there' shall' . be paid td the holder of this Nete attorney tees In the amount of $1;500.00, court costs a~d other expenses Incurred by the holder 'I~ enforcing the 'terms of ,thl,s Note.' , . ' Failure to pay any part of the prln~lpal 'or Interest of this Note whe~ due shal I authorize the holder of this Note to declare as Immediately due and payable, In addition to all obligations accrued hereunder, the then unpaid princIpal and Interest and to exercise al I other rights and remedies eIther at law or In equity possessed by the holder of this Note. The makers, signers and endorsers of this Note severally waive demand, presentment, notice of dishonor, diligence In collection, and notice of protest, and agree to all extensions and partial payments before or after maturIty, without prejudice to the holder. , . EXHIBIT "A" .. :, " . 'f' ., The maker'of this Note authorizes any attorney-at-law to appear before the Prothonotary of any Court of record of the Commonwealth of Pennsylvania or In any other Commonweal th or State In the United States at anytime after this Note becomes due, whether by acceleration ~'or otherwise, and to waive the Issuing and service of process and <"confess a jUdgment In favor of the legal holder against any maker and endorser, for the amount of principal and Interest then appearing due on this Note, together with costs of suit and attorney fees aforesaid, and to release all heirs and waive all right of appeal. Entry of judgment upon this Note by confession shal I not exhaust the authority for further entries of judgment In favor of any legal holder against any maker or endorser for the amount of principal and Interest then appearing due on this Note, tog,ether with costs of suit and attorney fees aforesaid, WARNING BY SIGNING THIS PAPER, YOU GIVE UP YOUR RIGHT T.O NO~ICE AND COURT TRIAL. IF YOU 'DO NO~ PAY ON'TIME, A COURT JUDGMENT MAY BE TAKEN AGAINST YOU WITHOUT YOUR PRIOR KNOWLEDGEj AND THE POWERS OF'A ~OURT CAN BE USED, TO COLLECT fROM YOU 'REGARDLESS OF ANY CLAIMS YOU MAY HAVE' ,AGAINST rHE CREDITOR, WHETHER FOR RETURNED GOODS, FAULTY GOODS, FAILURE,TO COMPLY WITH THE AGREEMENT OR ANY' OTHER CAU5E.' I N WI TNESS WHEREOF, the unde'rs I gned has hereun to' se t his hand and seal the ~~ 25th day of August, 1992. ~Mn1 _ ~. -Bnr&-,-- S nature ason D. Pooler S~~' jJ~ Judith B. Pooler -2- " .' '''CO'''~T..~'J:''ST;''~~'6:? ...~..o..:,~'lfW'r:"""" ....~.~;". PROTHONOTARY " 1'.' ~n'1 1" . ,", . .',\;)