HomeMy WebLinkAbout10-4369SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
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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,
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RON R ANDERSON, SHERIFF
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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 ~'~`/
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~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