HomeMy WebLinkAbout11-5360SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff 'FILED-OFFICE
Jody S Smith 4L?,;1r of an,t+rrf,?ri 0, THE PROTHONO !'ARC,
Chief Deputy - 2Q I I JUL I I AM 11: 21
Richard W Stewart
Solicitor F ` T" --REFF CUMBERLAND COUNTY
PENNSYLVANIA
Metro Bank
vs. Case Number
Dusan Bratic (et al.) 2011-5360
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: 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 a d correct copy of the same.
AM A COBAUGH, DEPU
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.
4J d a ? OAL JA,?,
A PD OBAUGH, DEPU
SHERIFF COST: $54.44
July 06, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
(ci CounfySuite Shecff. Te!ecsu+t. J?-,
METRO BANK, f/k/a Commerce
Bank/Harrisburg, N.A.
Plaintiff
V.
DUSAN BRATIC and
KATHLEEN M. BRATIC
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOCKET NO. 11-5360 CIVIL
RULE TO SHOW CAUSE
AND NOW, this 16 M day of , 2011, it is hereby ORDERED that:
1. A Rule is issued upon Respondent to show cause, if any it has, why the
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Judgment entered in the above-captioned matter should not be opened and the
defenses of the Petitioner be permitted;
2. The Respondent shall file an Answer to the Petition to Open Judgment within
A 0 . days from the days of service upon the Respondent;
3. The Petition shall be decided under Pa.R.C.P. 206.7;
4. Depositions shall be completed within 60 days of this date;
5. Argument shall be held on 114' , 202/ in Courtroom No. y
of the
jdq4 ounty Courthouse; A. d U7J /o.
6. Notice of the entry of this Order shall be 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.
J.
Distribution List:
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 00A
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`UMBERLAND COUNTY
PENNSYLVANIA
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
hzkellygmette.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. 11-5360-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:
1. 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.
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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
C. 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. KVtLY, E 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
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
T
By: 131
HEATHER Z. KftLY, 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
f`
METRO BANK, f/k/a COMMERCE IN THE COURT OF COMMON PLEAS OF
BANK/HARRISBURG, N.A., CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff,
DOCKET NOS. 11-jj360 - CIVIL
V. : -? -- r
DUSAN BRATIC and KATHLEEN z? c-) rorn
BRATIC, -?<D to °
Defendants c
-? =:-n
ORDER
-1
AND NOW, this day of August, 2011, upon Plaintiff's, Metro Bank, Wa o .:r
K
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
The He
at 2:00 p.m.
. 1-1-1,4-
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
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