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Home My WebLink About11-5363Principal: $328,680.46 Interest through 6/22/2011 $2,213.32 Late Charges*: $2,234.63 Attornevs' Commission: $33,089.38 *Continues to accrue until paid TOTAL $366,217.79 Interest at the per diem rate of $50.22, attorney fees and costs of this action continue to accrue. Respectfully submitted, &h'-e2 ?-z &AZ Heather Z. Kel , Esquire I.D No. 86291 Appearing herein for Defendant Mette, Evans & Woodside 3401 North Front Street P.O. BOX 5950 Harrisburg, PA 17110-0950 Telephone: (717) 232-5000 Date: June79, 2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFP; F `- :,.GRUFF FILED-OFFICE =;F THE PROTHON 1A ?` 2011 JUL I I AM I ! : 21 CUMBERLAND COUNTY PENNSYLVANIA Metro Bank Case Number vs. 2011-5363 Dusan Bratic 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 and correct copy of the same. AMANDA COBAUGF , EPUTY SHERIFF COST: $38.44 July 06, 2011 SO ANSWERS, RON ~ R ANDERSON, SHERIFF . Cou!..fySuite ShC' 1. Te'.ecso4. I.';; I METRO BANK, f/k/a Commerce Bank/Harrisburg, N.A. Plaintiff V. DUSAN BRATIC Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 11-5363 CIVIL D?6 ce `. d+n ,roll 4x&_116 PM *AM ? RULE TO SHOW CAUSE AND NOW, this /6-'fday of 2011, it is hereby ORDERED that: 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 4220 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 days of this date; 5. Argument shall be held on a / , 20/1 in Courtroom No. of the Ink Cou ty Courthouse; I 0-d p • rr1 . 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. ZA6k 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 _D-OFF ROTHONOTA{ i 1111 AUG 29 AM 10: 1+ 1 CUMBERLAND 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 hikelly@mette.com Attorneys for Plaintiff METRO BANK, f/k/a COMMERCE BANK/HARRISBURG, N.A., Plaintiff, V. DUSAN BRATIC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NOS. 11-5363- CIVIL 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 both 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. 542279v1 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 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 Defendant, Dusan Bratic, 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 Rules to Show Cause. Respectfully submitted, METTE, EVANS & WOODSIDE By: hIp-oz-d" -?- HEATHER Z-kELLY,fSQUIRE 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: xj".a& ? &'_4 "' HEATHER Z. KI?LLY, ES IRE 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 METRO BANK, Vk/a COMMERCE BANK/HARRISBURG, N.A., Plaintiff, V. DUSAN BRATIC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNgL N DOCKET NOS. 11-5363 - CIVII 2m = ) p Cz X- t~{ ORDER AND NOW, this day of August, 2011, upon Plaintiffs, Metro Bank, fWa 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: 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. z' /? Z- The H orable Kevin A. Hess Distribution List: / Prothonotary i 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 (Ppies iKa-plod ,r 4 METRO BANK, f/k/a COMMERCE IN THE COURT OF COMMON PLEAS OF BANK/HARRISBURG, N.A., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, NO. 11-5363 CIVIL V. DUSAN BRATIC, Defendant ORDER AND NOW, this ZSr day of October, 2011, upon the Joint Motion to Stay Pending Chapter 11 Bankruptcy, IT IS HEREBY ORDERED that the above captioned matter is stayed as to all parties for the duration of Bankruptcy No. 1: 11 -bk-06413-RNO pending in the United States Bankruptcy Court or until further Order of this Court. Within fifteen (15) days of the conclusion of the above-referenced Bankruptcy proceedings, the parties will notify the Court of their intent to proceed or discontinue the above- referenced matter. Distribution List: Prothonotary ? Heather Z. Kelly, Esquire, Mette, Evans & Woodside, 3401 N. Front Street, P.O. Box 5950, Harrisburg, PA 17110-0950; hzkelly_gmettexom; phone number (717) 232-5000 / Dusan Bratic, Esquire, Bratic and Portko, 101 Office Center, Suite A, 101 South U.S.;Rout? 15 Dillsburg, PA 17019; phone number (717) 432-9706 le Owes NU ,d ID la?,'?r OK,P s _. Y -77 544135v1