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CATDBank\.Shetron\2958.1 Affidavit.doo3
LUNDY, FLITTER, BELDECOS & BERGEMINT.EB - 8 RMTbAEYS FOR PLAINTIFF
By: PHILLIP D. BERGER, ESQUIRE GOUNTY
Identification Number: 58942
450 N. Narberth Avenue
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Narberth, PA 19072-0278
(610) 668-0770
----------------------------------------
TD BANK, N.A.,
Successor to Commerce Bank, N.A.
Plaintiff,
V.
KIRK A. NAUGLE
and
RAYMOND P. CULLEN
Defendants._
NO. 12-146 Civil Term
AFFIDAVIT OF SERVICE
1X('1tJERLAn1J
PENNSYLVANIA
Phillip D. Berger, Esquire, counsel for plaintiff, being duly sworn according to law,
hereby states:
1. On January 18, 2012 a 2958.1 Notice in the above matter was sent and served by
certified mail, to defendant Raymond P. Cullen at 609 W. King Street, Shippensburg, PA 17257.
A true and correct copy of the Notice is attached hereto and made a part hereof as Exhibit "A."
2. The Notice was received at the defendant Raymond P. Cullen's last known
residence on January 27, 2012 as evidenced by the signature on the return receipt attached hereto
and made a part hereof as Exhibit "B."
3. Therefore, the defendant Raymond P. Cullen was properly served with the 2958.1
Notice in this action pursuant to Pennsylvania Rules of Civil Procedure 2958.1(b)(ii) and 403.
Sworn to and subscribed
before me this 3 day
of February, 2012.
Notary Public
GOWONWEALT?l OF PENNSYLVANIA
Notarial Seas
Sandra i_ Tru;t;rcn, Notary Public
Narberh Elm- t;1 rotrcmery County
'+?, r.,r;;ms n G ai.;ne 9, 2013 _
Merr ur F; n", >u If N,ctarie I
LUNDY, FLITTER, BELDECOS & BERGER, P.C.
l-
By:
PHILLIP D. BERGER, ESQUIRE
EXHIBIT A
CATDBank\Shetron\2958.1 Notice.&O
LUNDY, FLITTER, BELDECOS & BERGER, P.C
By: PHILLIP D. BERGER, ESQUIRE
Identification Number: 58942
450 N. Narberth Avenue
Narberth, PA 19072-0278
(610) 668-0770
TD BANK, N.A.,
Successor to Commerce Bank, N.A.
1701 Route 70 East
Cherry Hill, NJ 08034
Plaintiff,
V.
KIRK A. NAUGLE
I100 Remington Drive
Shippensburg, PA 17257
and
RAYMOND P. CULLEN
609 W. King Street
Shippensburg, PA 17257
Defendants.
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ATTORNEYS FOR PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 12-146 Civil Term
NOTICE UNDER RULE 2958.1 OF
JUDGMENT AND EXECUTION THEREON
VIA CERTIFIED MAIL ONLY
TO: RAYMOND P. CULLEN
609 W. King Street
Shippensburg, PA 17257
A judgment in the amount of $62,797.78 has been entered against you and in favor of TD
Bank, N.A., successor to Commerce Bank, N.A. without any prior notice or hearing based on a
confession of judgment contained in a written agreement or other paper allegedly signed by you.
The Sheriff may take your money or other property to pay the judgment at any time after thirty
(30) days after the date on which this notice is served on you.
You may have legal rights to defeat the judgment or to prevent your money or property
from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE
JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE
DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR
RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER AND CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Services
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013-3302
(717) 249-3166
By:
LUNDY, FLITTER, BELDECOS & BERGER, P.C.
(?OT
PHILLIP D. BERGER, ESQUIRE
Attorneys for Plaintiff
Dated: i /I
?/?
/ i
Complete items 1, 2, and 3. Also complete
Item 4 if Restricted Delbay is desired.
Print your name and address on the reverse
so that we can return the card to you.
Attach this cad to the back of the mailpiece,
or on the front N space permits.
1. Article Addressed to:
RAYMOND P. CULLEN
609 W. King Street
Shippensburg, PA 17257
2. Article Number
(rrarbr Sam swwfte 16bel)--
Ps Form 3811, February 2004
7011 0470
13 Agent
B. Received by (Pr6rted Name) C. Date of Delivery
D. Is delivery address different from item 1? 11 Yes
If YES, enter delivery address below: 0 No
I
3. Service Type
Certified Mail 0 Express Mail
0 Repistared ? Return Receipt for Mercimixilse
O Insured Man ? C.O.D.
i
4. Restrkted Delivery? P" AW) p yes {
0000 3383 t
4382
Domestic Return Receipt
102595-024&1540
EXHIBIT B
C:\TDBank\Shetron\OrdertSatisfyJudgmmt.doe
BERGER LAW GROUP, PC
By: PHILLIP D. BERGER, ESQUIRE (#58942)
JESSICA M. GULASH, ESQUIRE (#208463)
450 N. Narberth Avenue
Narberth, PA 19072-0278
(610) 668-0800
TD BANK, N.A.,
Successor to Commerce Bank, N.A.
1701 Route 70 East
Cherry Hill, NJ 08034
Plaintiff,
V.
KIRK A. NAUGLE
1100 Remington Drive
Shippensburg, PA 17257
and
RAYMOND P. CULLEN
609 W. King Street
Shippensburg, PA 17257
Defendants.
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ATTORNEYS FOR PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 12-146 Civil Term
ORDER TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Uy cr% C)
yol N fir`'
4 CO
Kindly satisfy the judgment against Defendants Kirk A. Naugle and Raymond P. Cullen
in the above-captioned action.
BERGER LAW GROUP, PC
By:
PHILLIP D. BERGER, ESQUIRE
Dated: