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Home My WebLink About10-7173SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff . Q`i`ltr c"it?r fart{440. FILED-OFFICE OF THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor Citizens Bank of Pennsylvania vs. Robert Goodrich 2010 DEC ^2 Ph 3: 4 5) CUMBERLAND COUNT PENNSYLVANIA Case Number 2010-7173 SHERIFF'S RETURN OF SERVICE 11/18/2010 03:24 PM - William Cline, Corporal, who being duly sworn according to law, states that on November 18, 2010 at 1524 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robert Goodrich, by making known unto Lisa Goodrich, Wife of defendant at 1595 W. Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. OMAR CLINE, DEPUTY SHERIFF COST: $37.44 November 19, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF _o Gxet'y5uite S"ne^,?f, Te+.^oscYt. h`.:. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIZENS BANK OF PENNSYLVANIA, Plaintiff, vs. ROBERT GOODRICH, Defendant. CIVIL DIVISION n " q i m M = M NO.: 10-7173 ?- - -° r -0o W oi r p --Ip C--) -- o - j TYPE OF PLEADING: Xc'7 Drry PRAECIPE FOR DEFAULT JUDGMENT (Breach of Contract) I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 443 Jefferson Boulevard Warwick, RI 02886 AND THE DEFENDANT IS: 1595 W. Lisburn Road Mechanicsburg, PA 17055 FILED ON BEHALF OF PLAINTIFF: Citizens Bank of Pennsylvania COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 1q, 60 -Piz:, 4 ek-? t 3t?llely a 53Ole 1 Nb?-Ce mo0ej IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIZENS BANK OF PENNSYLVANIA, CIVIL DIVISION Plaintiff, NO.: 10-7173 VS. ROBERT GOODRICH, Defendant. PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Robert Goodrich, in the amount of $104,435.90, which is itemized as follows: Principal $99,000.00 Interest to 10/14/10 $ 4,571.87 Late Charges to 10/14/10 $ 864.03 TOTAL $104,435.90 with interest on the principal sum ($99,000.00) from October 14, 2010 at the Default Rate of Interest equal to $17.18 per diem (as may change from time to time in accordance with the Note, as modified by the Modification), together with costs and reasonable and actually incurred attorney's fees. GRENEN & BIRSIC, P.C. AFFIDVAIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth personally appeared Joseph A. Fidler, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant was not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237. 1, as evidenced by the attached copy: Sworn and subscribed before me this 3?hday of , 2010. iu6k &-?'Mxnn otary Public CoMMONWEAL FI PENNSYLVANIA Notarial Seal Elizabeth M. Cagnon, Notary Public city of Pittsburgh, Allegheny County My Cwtra,,3;ion Expires Jan. 6, 2012 +s^n?atlon of Notarle: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CITIZENS BANK OF PENNSYLVANIA, CIVIL DIVISION Plaintiff, vs. NO.: 10-7173 ROBERT GOODRICH, Defendant. TO: Robert Goodrich 1595 W. Lisburn Road Mechanicsburg, PA 17055 DATE OF NOTICE: December 9, 2010 IMPORTANT NOTICE 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 GRENENj& BIRSIC, P FIRST CLASS MAIL, POSTAGE PREPAID By: s" for Plaintiff e Gateway Center, Ninth Floor ittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIZENS BANK OF PENNSYLVANIA, CIVIL DIVISION Plaintiff, VS. ROBERT GOODRICH, Defendant. NO.: 10-7173 NOTICE OF ORDER. DECREE OR JUDGMENT TO: Robert Goodrich, President 1595 W. Lisburn Road Mechanicsburg, PA 17055 ( ) Plaintiff (XX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above-captioned proceeding on ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $104,435.90 with interest on the principal sum ($99,000.00) from October 14, 2010 at the Default Rate of Interest equal to $17.18 per diem (as may change from time to time in accordance with the Note, as modified by the Modification), together with costs and reasonable and actually incurred attorney's fees. Deputy IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Citizens Bank of Pennsylvania Plaintiff, v. Robert S. Goodrich Defendants Case No.: 10-7173 SUGGESTION OF PENDING BANKRUPTCY PROCEEDINGS A voluntary petition under Chapter 7 of the United States Bankruptcy Code was filc;d in the Bankruptcy Court for the Middle District of Florida, Tampa Division, on ~ c ~l~=tic w _~ N _, 2012, which case is captioned: In re: Robert Goodrich and Lisa Goodrich Chapter 7 Case No.: `~ ' i ~ b K [ ~ (:' ~; 1 The filing of this Suggestion does not constitute a Notice of Appearance in these proceedings. The undersigned represents the Defendant in connection with a federal bankruptcy case, as referenced above, and is providing this Suggestion for informational purposes only. Respectfully sub fitted, - G. D d den, Fla. Bar No.: (i 137080 - - do@brandonlawyer.com Joseph B. Battaglia, Fla. Bar No.: 00.58199 joe@brandonlawyer.com THE GOLDEN LAW GROUP 808 Oakfield Drive, Suite A Brandon, Florida 3351 1 Telephone: (813) 413-8700 Facsimile: (813) X13-8701 Bankruptcy Counsel for Defendants CERTIFICATE OF SERVICE [ HEREBY CERTIFY THAT, on this 31 day of ~.~C ~e~i- ~" 2012, a true and correct copy of the foregoing has been provided via mail to; Attorney for Plai tiff; Grenen & Birsic, P.C., One Gateway Center, Ninth Floor, Pittsburgh, PA 15222. ~~ ~ G./bk5nald`Golden, Fla. Bar No.: (1137080 J seph B. Battaglia, Fla. Bar No.: 0058199