SPECTOR GADON & ROSEN
BY: Alan S. Fellheimer
Identification No.: 09842
BY: David F. Gould, III
Identification No.: 48046
1700 Market Street
29th Floor
Philadelphia, PA 19103
(215) 241-8888 Attorneys for Plaintiff
_______________________________________________________________
J.L. WOLGIN : COURT OF COMMON PLEAS
: OF LUZERNE COUNTY
:
Plaintiff, :
:
V. : ,1991
:
C.B.G. LIMITED :
Defendant. : NO. 2326-L
AVERMENT OF DEFAULT
COMMONWEALTH OF PENNSYLVANIA :
: SS.
COUNTY OF PHILADELPHIA :
I J.L. Wolgin being duly sworn according to law, depose
and say that I am the plaintiff herein and that the defendant
entered into a Promissory Note ("Note") dated June 28, 1991, in the
principal sum of $2,000,000.00. True and correct copies of the
Note and the Mortgage are attached hereto and marked as Exhibit A
and Exhibit B, respectively.
I further state that the Mortgage and Note are in
default, and plaintiff has accelerated all sums due so that there
is now due and owing under the Mortgage and Note $1,335,333.33
including interest and late fees as of August 1, 1991, plus
attorneys' fees of 5 percent of principal amount due.
/s/
_____________________
J.L. Wolgin
Sworn to and subscribed
before me this 8th day of
August, 1991
/s/
__________________
Notary Public
NOTARIAL SEAL
JUDITH P LAWRENCF Notary Public
City Of Philadelphia, Phila. County
My Commission Expires Oct. 14,1991
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