Safrin v. Travaini Pumps USA, Inc.

Opinion by KOONTZ, Justice.

In this appeal, the dispositive issue we consider is whether more than 21 days after the entry of a confessed judgment pursuant to Code § 8.01-432, the trial court had jurisdiction to modify that judgment by entering an award of liquidated attorney's fees.

BACKGROUND

On November 13, 2002, Robert E. Safrin executed a promissory note in favor of Travaini Pumps USA, Inc. (Travaini Pumps) in the principal sum of $59,000. The note provided that the principal was to be paid without interest in 12 monthly installments. In the event of a default, a provision of the note…