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HomeMy WebLinkAbout10-4369SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOiICItOr ~~~atti, of ~ir,r~br~~ C°r ~>. `' ' -r C>FfiCE < -.<E ~.r~RIFF f=i~~i; - ~`: 2010 J.G~ --~ F~ ~ ~~ 3~ Target National Bank vs. Daniel C. Zielinski Case Number 2010-4369 SHERIFF'S RETURN OF SERVICE 07/07/2010 08:46 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 7, 2010 at 2046 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Daniel C. Zielinski, by making known unto himself personally, at 5 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. A COBAUGH, DE SHERIFF COST: $37.00 July 08, 2010 SO ANSWERS, ... `~~-- RON R ANDERSON, SHERIFF {c~ GountySuite Sherlft. ieleosoft. Inc. -.~ r ,-~._._ T ~n~ ~_-: ~'!3 Pmt 3 •• ~ CUf " ~. .. ;;;~,, r k `a~ ,_ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 2010-04369 v. DANIEL C ZIELINSKI Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 ~I~.oo P p ~'~`/ e~` ~1'1~F8 ~,~ aylo'11~I ~lo~Cee ~.(a:~.d PA_119 Prcp Def Jg Both P&F File No. 09-54912 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff v. DANIEL C ZIELINSKI Defendant(s) NO. 2010-04369 PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY Please enter a judgment against the defendant, above named, for failure to file an Answer to Plaintiff s complaint. Amount claimed in Complaint Interest from May 27, 2009 Less payments received Attorney's fees TOTAL $11,308.50 $0.00 $0.00 $0.00 $11,308.50 With continuing interest on the principal amount of $11,308.50, with interest at the legal rate, plus costs of suit. I hereby certify that a written notice of intention to file this praecipe was mailed to the defendants and defendants' counsel (if known), after the default had occurred and at least ten (10) days prior to the date of the filing of this praecipe. A copy of the Notice is attached. Respectful ly~tfiJ~mitted: A.P.C. Date: August 09, 2010 213 ain Street Carn ' , PA 15106 (412 29-7675 PA_l 19 Prcp Def Jg Both P&F File No. 09-54912 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff v. DANIEL C ZIELINSKI Defendant(s) NO. 2010-04369 PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA.R.C.P. 1037(jZ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared GREGG MORRIS, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and states that the defendant(s), DANIEL C ZIELINSKI, is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that Notice of Intent to take Default Judgment was mailed in accordance with Pa.R.C.P.237.1, as evidenced by the attached copy. Respectful ly,~ubmitted: Date: August 09, 2010 Sworn to and subscribed before me this day of , 20~. Notary Pub is elix, A.P.C. 3 /E/Main Street Cai~gie, PA 15106 (412) 429-7675 COMMONWEALTH OF PENNSYLVANIA NofarW Sal CArolyn J. Stwvart, Notary Publb ~~C won ExpM.1~~11 PA_120 Aff of oN n Ml ' Pam ~'l ~ P&F File No. 09-54912 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 2010-04369 v. DANIEL C ZIELINSKI Defendant(s) IMPORTANT NOTICE Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Pariy: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_I 13 10 Day Dl D2 P&F File No. 09-54912 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 2010-04369 v. DANIEL C ZIELINSKI Defendant(s) To: Daniel C Zielinski 5 Woods Dr Mechanicsburg PA 17050-2748 Date of Notice: July 28, 2010 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 PA 17013 717-249-3166 Patenaude,6c ~'elixlA.P.C. Date: July 28, 2010 is, Esquire 15106 5 PA_I 13 10 Day Dl D2 P&F File No. 09-54912 I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK ,hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: Daniel C Zielinski 5 Woods Dr Mechanicsburg PA 17050-2748 Date: July 28, 2010 Mo Esquire . Main Stree ~egie, PA 15106 429-7675 PA_113 10 Day D1 D2 P&F File No. 09-54912 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 2010-04369 v. DANIEL C ZIELINSKI Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412} 429-7675 PA_123 Ntc Jgmt Both P&F File No. 09-54912 IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 2010-04369 v. DANIEL C ZIELINSKI Defendant(s) NOTICE OF ORDER DECREE OR ~ji1DGMENT AGAINST DANIEL C ZIELINSKI ONLY TO: ( )Plaintiff (x )Defendant ( )Garnishee ( )Additional Defendant You are hereby notified that the following Order, Decree, or Judgment has been entered against you on 8~13~/0 ( )Decree Nisi in Equity ( )Final Decree in Equity (X) Judgment of ( )Confession ( )Verdict ( )Court Order (X) Default ( )Non-suit ( )Non-Pros ( )Arbitration Award (X) Judgment in the amount of $11,308.50, plus costs. ( )District Justice Transcript of Judgment in the amount of $ , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Protho tary If you have questions concerning the above, please Contact: Name of Attorney: GREGG MORRIS, Esquire 213 East Main St Carnegie PA 15106 (412)-429-7675 By ~ Deputy L~awicL . ~u PA_123 Ntc Jgmt Both P&F File No. 09-54912