Loading...
HomeMy WebLinkAbout12-0147iLED-OFFICE Cr= THE F'ROTNONOTAR` C:\TDl3ank\Shetron\2958.1 Affidavit.doc2 FF Q LUNDY, FLITTER, BELDECOS & BERGE 1 PV ! PMV?T c) MNEYS FOR PLAINTIFF By: PHILLIP D. BERGER, ESQUIRE CUMBERLAND COUNTY Identification Number: 58942 PENNSYLVANIA 450 N. Narberth Avenue Narberth, PA 19072-0278 (610) 668_0770 , ---------------------------- TD BANK, N.A. V, Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY SHETRON WELDING & FABRICATION, INC. and KIRK A. NAUGLE and RAYMOND P. CULLEN Defendants. ---------------------------------------- NO. 12-147 Civil Term AFFIDAVIT OF SERVICE 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. LUNDY, FLITTER, BELDECOS & BERGER, P.C. Sworn to and subscribed before me this day of February, 2012. By: PHILLIP D. BERGER, ESQUIRE Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sandra L. Trudgeon, Notary Public Narberth Soro, Montgomery County My Commission Endres June 9, 2013 Member, Pei ^f Notaries EXHIBIT 8 CATDBank\Shetron\2958.1 Notice.doc2 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. 1701 Route 70 East Cherry Hill, NJ 08034 Plaintiff, V, SHETRON WELDING & FABRICATION, INC. 85 Kutz Road Carlisle, PA 17013 and KIRK A. NAUGLE I100 Remington Drive Shippensburg, PA 17257 and RAYMOND P. CULLEN 609 W. King Street Shippensburg, PA 17257 Defendants. ATTORNEYS FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 12-147 Civil Term NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON VIA CERTIFIED MAIL ONLY TO: RAYMOND P. CULLEN 609W. King Street Shippensburg, PA 17257 A judgment in the amount of $151,517.58 has been entered against you and in favor of TD 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 LUNDY, FLITTER, BELDECOS & BERGER, P.C. By: PHILLIP D. BERGER, ESQUIRE Attorneys for Plaintiff Dated: 001/ f Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery Is desired. Print your name and address on the reverse so that we can return the card to you. Attach this card to the back of the mallpiece, or on the front if space permits. 1. Article Addressed to: RAYMOND P. CULLEN 609 W. King Street Shipp!nsburg, PA 17257 A. B. Received by (Printed Name) I C. Date of D. b delivery address different from item 17 ' ?Ye< If YES, enter delivery address below: ? No ? Agent 3. Servioe Type Certified Mall ? Express mail ? Registered ? Return Reoeipt for Merchandise ? insrred mail ? C.O.D. I 4. Restricted Delivery? (Extra Fee) ? Yes I 1 2. Article Number (Tranallerirvrrrservlce/rl,5 711 0470 0000 3383 4337 i PS = 38'1 ;°FeWuarjr,2004 Domestie Retum Reoeipt ta¢Ms W4f-1540 4 i EXHIBIT B C:\TDBank\Shetron\OrderPartiallySatisfy.da: 1 P BERGER LAW- GROUP, PC ,vL 26iT?71ri?tEYS FOR PLAINTIFF By: PHILLIP D. BERGER, ESQUIRE (#5) ND CQt?N?Y JESSICA M. GULASH, ESQUIRE (#2p0 N IASO ,N1A 450 N. Narberth Avenue Narberth, PA 19072-0278 (610) 668-0800 TD BANK, N.A. 1701 Route 70 East Cherry Hill, NJ 08034 Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY V. SHETRON WELDING & FABRICATION, INC. 85 Kutz Road Carlisle, PA 17013 and KIRK A. NAUGLE I100 Remington Drive Shippensburg, PA 17257 and RAYMOND P. CULLEN 609 W. King Street Shippensburg, PA 17257 Defendants. NO. 12-147 Civil Term ORDER TO PARTIALLY SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly satisfy the judgment against Defendants Kirk A. Naugle and Raymond P. Cullen, only, in the above-captioned action. The judgment against Defendant Shetron Welding & Fabrication, Inc. shall remain in full force and effect. BERGER LAW GROUP, PC By: PHI LIP D. BERGER, ESQUIRE Dated: ?? uqsb? t coJW7 a?ssoy 0-H