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Home My WebLink About11-5359SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor d 'T THE PROH FILED-OFFICE 2011 JUL I I AM 11= 21 CUMBERLAND COUNTY PENNSYLVANIA Metro Bank i vs. Dusan Bratic (et al.) Case Number 2011-5359 SHERIFF'S RETURN OF SERVICE 07/05/2011 08:15 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 5, 2011 at 2015 hours, she served a true copy of the within Complaint in Confession of Judgment and Notice, upon the within named defendant, to wit: Kathleen M. Bratic, by making known unto herself personally, at 5609 Pinehurst Way, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. AMA DA COBAUGH, DEPUTY-) 07/05/2011 08:15 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 5, 2011 at 2015 hours, she served a true copy of the within Complaint in Confession of Judgment and Notice, upon the within named defendant, to wit: Dusan Bratic, by making known unto Kathleen Bratic, Wife of Defendant at 5609 Pinehurst Way, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $54.44 July 06, 2011 JaLlb, 0_9? - AMANDA COBAUGH, DEPU SO ANSWERS, RON R ANDERSON, SHERIFF ,c; Goun'ySu[to, Sf' eref. (eiecso+t. Int. METRO BANK, f/k/a Commerce Bank/Harrisburg, N.A. Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DUSAN BRATIC and DOCKET NO. 11-5359 CIVIL C= 7 KATHLEEN M. BRATIC' ?- y--! Defendants r_ RULE TO SHOW CAUSE ^° AND NOW, this day of , 2011, it is hereby ORDERED that: 1. A Rule is issued upon Respondent to show cause, if an it has by the , Judgment entered in the above-captioned matter should not be o opened and th e defenses of the Petitioner be permitted; 2. The Respondent shall file an Answer to the Petition to Open Judgment withi n e-W _ days from the days of servi ce upon the Respondent; 3. The Petition shall be de id c ed under Pa.R.C.P. 206.7; 4. Depositions shall be completed within days of this date; 5. Argument shall be held on 20 in Courtroom No. of the ounty Courthouse; aZt c ? OO,.p m - 6. Notice of the entry of is Order shall b e provided to all parties by the Petitioner, and 7. All proceedings, including all executions on the judgment docketed hereto are stayed pending this Court's review and determination of the Petition to Open Judgment and rulings thereon and the entry of an Order dissolving such Stay. Distribution List: J. Prothonotary ?Dusan Bratic, Esq. 101 South US Route 15, Dillsburg, PA 17019 ,/Heather Kelly, Esq. Mette, Evans & Woodside, 3401 N. Front St., PO Box 5950, Harrisburg, PA 17110-0950 ?op ie5 #1146 E O Alt '. - " T H04 o _ 2J :tq.48ERLAND COUNTY ENNSYLVANIA METTE, EVANS & WOODSIDE Heather Z. Kelly, Esquire Sup. Ct. ID No. 86291 3401 N. Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Facsimile hzkelly_gmette.com Attorneys for Plaintiff METRO BANK, f/k/a COMMERCE BANK/HARRISBURG, N.A., Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET NOS. 11-5359-CIVIL V. DUSAN BRATIC and KATHLEEN BRATIC, Defendants MOTION FOR EXTENSION OF TIME Plaintiff, Metro Bank f/k/a Commerce Bank/Harrisburg, N.A., by their counsel, Mette, Evans & Woodside, files the following Motion for Extension of Time of the August 16, 2011 Rules to Show Cause and aver in support: On August 16, 2011, the Honorable Court issued identical Rules to Show Cause with regard to all of the above-referenced matters. 2. Counsel for the parties are actively engaged in negotiations in an attempt to settle all of the above-referenced actions. 542271v1 In an effort to contain costs of litigation, counsel for the parties jointly request an extension of time of the deadlines contained in the August 16, 2011 Rules to Show Cause as follows: a. The deadline for Plaintiff to file Answers to the Petitions to Open Judgment is extended to September 30, 2011 b. The deadline for taking depositions, if sought, is October 16, 2011 As previously scheduled, argument shall be held on October 21, 2011, in Courtroom No. 4 of the Cumberland County Courthouse at 2:00 p.m. 4. Counsel for the Defendants, Dusan Bratic and Kathleen Bratic, do not oppose this Motion. WHEREFORE, Plaintiff, Metro Bank, f/k/a Commerce Bank/Harrisburg, N.A. respectfully requests this Honorable Court enter an Order extending the deadlines of the August 16, 2011 Rules to Show Cause. Respectfully submitted, METTE, EVANS & WOODSIDE By: HEATHER Z. KIKLY, ESQUIRE Sup. Ct. I.D. No. 86291 3401 North Front Street P. O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Fax Attorneys Plaintiff, Metro Bank f/k/a Commerce Bank/Harrisburg, N.A. Date: August 26, 2011 2 CERTIFICATE OF SERVICE I certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage, prepaid, as follows: Dusan Bratic, Esquire BRATIC and PORTKO 101 South Office Center, Suite A 101 South U.S. Route 15 Dillsburg, PA 17019 Respectfully submitted, METTE, EVANS & WOODSIDE By: <. HEATHER Z. KE LY, ES UIRE Sup. Ct. I.D. No. 86291 3401 North Front Street P. O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Fax Attorneys Plaintiff, Metro Bank f/k/a Commerce Bank/Harrisburg, N.A. Date: August 26, 2011 i METRO BANK, f/k/a COMMERCE IN THE COURT OF COMMON PLEAS OF BANK/HARRISBURG, N.A., CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff, n - ,,? DOCKET NOS. 11 359 - CIVIL V. I =r r - 2? U)r- c7 r ern DUSAN BRATIC and KATHLEEN BRATIC, r - -?o Defendants v T - 7a r Fi CD rt ORDER AND NOW, this 7' day of August, 2011, upon Plaintiff s, Metro Bank, f/k/a Commerce Bank/Harrisburg, N.A. Motion for Extension of Time, IT IS HEREBY ORDERED that the following dates of the August 16, 2011 Rules to Show Cause filed in the above- referenced matters are extended as follows: 1. The deadline for Plaintiff to file Answers to the Petitions to Open Judgment is extended to September 30, 2011 2. The deadline for taking depositions, if sought, is October 16, 2011. 3. As previously scheduled, argument shall be held on October 21, 2011, in Courtroom No. 4 of the Cumberland County Courthou at 2:00 p.m. The Ho"ndrable Kevin A. Hess Distribution List: Prothonotary Heather Z. Kelly, Esquire, Mette, Evans & Woodside, 3401 N. Front Street, P.O. Box 5950, Harrisburg, PA 17110-0950; hzkellygmette.com; phone number (717) 232-5000 ,'Dusan Bratic, Esquire, Bratic and Portko, 101 Office Center, Suite A, 101 South U.S. Route 15, Dillsburg, PA 17019; phone number (717) 432-9706 06PO-2:- oat' Da 4 U