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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:
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