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Home My WebLink About11-5361SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 1` ELE D-OE= t' IC 26 11 JUL 26 AM 8: t4 7 r",UMBERLANG, CO ET",I" °ENNSYLVANlik Metro Bank VS. John T. Kocher Case Number 2011-5361 SHERIFF'S RETURN OF SERVICE 07/01/2011 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: John T. Kocher, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Complaint In Confession of Judgment and Notice according to law. 07/19/2011 09:57 AM - Dauphin County Return: And now July 19, 2011 at 0957 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Confession of Judgment and Notice, upon the within named defendant, to wit: John T. Kocher by making known unto himself personally, at 960 Mountain Road, Dauphin, Pennsylvania 17018 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.44 July 25, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF i ?OU COMMON PLEAS METRO BANK, f/k/a Commerce IN THE COURT Bank/Harrisburg, N.A. CUMBERLAND Plaintiff DOCKET NO. 11-5361 CIVIL -? - = s JOHN T. KOCHER> Defendant f ? `'LL' RULE TO SHOW CAUSE c , Z AND NOW, this Ap day of QAQ(, 2011, it is hereby ORDERED that:' (, y r 1. A Rule is issued upon Respondent to show cause, if any it has, why the 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 ?2d 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 &0 days of this date; 5. Argument shall be held on 20 // in Courtroom No. of the County Courthouse,; OU7& , m- 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. 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 ?P ? ,s ?';f;' ?3t L?+E`D COUNT r'?P????Y! ?'P,4dlA 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_(a)mette.com Attorneys for Plaint METRO BANK, f/k/a COMMERCE IN THE COURT OF COMMON PLEAS OF BANK/HARRISBURG, N.A., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, DOCKET NO. 11-5361 - CIVIL V. JOHN T. KOCHER, Defendant 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 a Rule to Show Cause with regard to the above-referenced matter. 2. Counsel for the parties are actively engaged in negotiations in an attempt to settle the above-referenced action. 54zo7zvi 3. 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 Rule to Show Cause as follows: a. The deadline for Plaintiff to file an Answer to the Petition 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 Defendant, John T. Kocher, does 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 Rule to Show Cause. Respectfully submitted, METTE, EVANS & WOODSIDE By:' ,?1 ttC?%? HEATHER Z. LLY, 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 24, 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. KELLY, 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 24, 2011 METRO BANK, f/k/a COMMERCE IN THE COURT OF COMMON PLEAS OF BANK/HARRISBURG, N.A., CUMBERLAND COUNTY, PENNS?VAN IA Plaintiff, c =- ?f DOCKET NO. 11-5361 - CIVIL rnCD v. cnr- "Yj ) JOHN T. KOCHER , Defendant .- ORDER „ AND NOW, this _-L/. 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 Rule to Show Cause filed in the above- referenced matter are extended as follows: 1. The deadline for Plaintiff to file an Answer to the Petition 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 Courthouse at 2:00 p.m. /10/? -,-x- /--,/ The Ho able 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; hzkelly@mette.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 ? YQ 4 FJ METRO BANK, f/k/a IN THE COURT OF COMMON PLEAS OF COMMERCE BANK/ CUMBERLAND COUNTY, PENNSYLVANIA HARRISBURG, N.A.., Plaintiff CIVIL ACTION - LAW V 2011-5352 CIVIL TERM PENNNNSULA, Inc., d/b/a PENINSULA, Inc., Defendant METRO BANK, f/k/a IN THE COURT OF COMMON PLEAS OF COMMERCE BANK/ CUMBERLAND COUNTY, PENNSYLVANIA HARRISBURG, N.A., Plaintiff CIVIL ACTION - LAW / V 2011-5361 CIVIL TERM V JOHN T. KOCHER, Defendant METRO BANK, f/k/a IN THE COURT OF COMMON PLEAS OF COMMERCE BANK/ CUMBERLAND COUNTY, PENNSYLVANIA, HARRISBURG, N.A., - Plaintiff CIVIL ACTION - LAW _i= o - 2011-5356 CIVIL TERM -r`+ ° V ---E PA MANOR, INC., Defendant = ' - IN RE: ENTRY OF APPEARANCE ` ORDER OF COURT AND NOW, this 21st day of October, 2011, the court notes the entry of an appearance of Dusan Bratic, Esquire, on behalf of John T. Kocher, PA Manor, Inc.., and Peninsula, Inc. This order is entered with the understanding that Mr. Bratic will. file written appearances in these cases within seven days. By the Court, Kevin A. Hess, P.J. ? Heather Z. Kelly, Esquire For the Plaintiff Dusan Bratic, Esquire For the Defendants lpJ°? Q.,Q . bg I.? :D OCT26 AN H.- ? r Dusan Bratic, Esq. PENNSYLVANIA Bratic & Portko 101 South US Route 15 Dillsburg, PA 17019 (717) 432-9706 (717) 432-9220 Fax METRO BANK, f/k/a Commerce IN THE COURT OF COMMON PLEAS OF Bank/Harrisburg, N.A. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. DOCKET NO. 11-5361 CIVIL JOHN T. KOCHER Defendant PRAECIPE FOR ENTRY OF APPEARANCE Please enter the appearance Dusan Bratic, Esquire, of the law firm of Bratic and Portko, on behalf of the Defendant. Bratic,& Portko Date: b - 5- Dusan Bratic, Esquire, ID 19249 101 South U.S. Route 15 Dillsburg, PA 17019 (717) 432-9706 Attorney for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above Praecipe to Enter Appearance was furnished by first class mail, postage prepaid on this 2?day of October 2011, to: Heather Z. Kelly, Esq. Mette, Evans & Woodside 3401 North Front St. P.O. Box 5950 Harrisburg, PA 17110-0950 C & PORTKO Dated: 10- 2 ?'- k Dus#n Bratic, Esq. ID # 19249 10 South U.S. Route 15 D' lsbura. PA 17019 (717) 432-9706 Attorney for Defendant