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Home My WebLink About14-0349 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 NO.: 13 -7033 MLD Plaintiff, NO.: 1 4-63 49 a i Term vs. NEDELJKO GUNJAK TYPE OF PLEADING 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 CIVIL ACTION - WRIT PARCEL #38 -21- 0289 -003 OF SCIRE FACIAS Defendant. FILED ON BEHALF OF: Silver Spring Township Authority, Plaintiff TO: DEFENDANT(s) COUNSEL OF RECORD FOR THIS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE PARTY: ENCLOSED WRIT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT Scott A. Dietterick, Esquire -' MAY BE ENTERE GAINST YOU. Pa. I.D. #55650 Kathryn L. Mason Esquire e Pa. I.D. #306779 -- y P.O. Box 650 �-- —; Hershey, PA 17033 ; (717) 533 - 3280 ATTO OR P TIFF I HEREBY CERTIFY THAT THE ADDRESS - OF THE PLAINTIFF IS: 5 Willow Mill Park Road, Suite 3 JSDC LAW OFFICES Mechanicsburg, PA 17050 AND THE DEFENDANTS: 228 Ho - wn Road Mecha icsbur , 50 A Y AINTIFF CERTIFICATE OF LOCATION I HEREBX CERTIFY THAT THE LOCATION OF THE RE ESTA FECTED BY THIS LIEN IS 228 Ho tow oad, echanicsburg, PA 17050 EY FOR PLAINTIFF d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, No.: 13 -7033 MLD VS. No.. NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 PARCEL ID# 38 -21- 0289 -003 Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249 -3166 Toll Free (800) 990 -9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, No.: 13 -7033 MLD VS. No.. NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 PARCEL ID# 38 -21- 0289 -003 Defendant. AVISO USTED HA SIDO DEMONDADO /A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249 -3166 Toll Free (800) 990 -9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, No.: 13 -7033 MLD VS. n No.. I - D3�q l�� v i�TPXYYI NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 C: n PARCEL ID# 38 -21- 0289 -003 Defendant. PRAECIPE TO ISSUE WRIT OF SCIRE FACIAS 'z c') ;7c. :v = .7 rn TO: PROTHONOTARY - Please issue a Writ of Scire Facias, against the Defendant, Nedeljko Gunjak, in the amount of $4,194.05, in the above - captioned matter. JSDC Law Offic Date: 1 � By: Scott A. Dietterick, Esquire PA ID #55650 33. !So P 6 AT 1Y Kathryn L. Mason, Esquire al 5 0 Lz PA ID #306779 - - PO Box 650 S5 .. oo PD Hershey, PA 17033 (717) 533 -3280 Attorneys for Plaintiff �a.as p�E c o $Q.Sa S AT. FIZ-' �# la y t�7 Cos (A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, No.: 13 -7033 MLD VS. '' ff No.: `t �� 0, V NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 = �i PARCEL ID# 38 -21- 0289 -003 r*j u - Defendant. Cn WRIT OF SCIRE FACIAS �_t - �r TO: NEDELJKO GUNJAK WHEREAS, Silver Spring Township Authority, on November 26, 2013, filed its claim in the Court of Common Pleas of Cumberland County at Municipal Claim No. 13 -7033 MLD, for the sum of $4,194.05, plus additional attorneys fees and costs incurred thereafter, for sewer rents due the said Silver Spring Township Authority, said Claim filed against property owned by you in Silver Spring Township, located at 228 Hogestown Road, Mechanicsburg, PA 17050, as more particularly described in said Claim, and said property being further described in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, as Instrument Number 200747830, tax parcel #38 -21- 028.9 -003, owned or reputed to be owned by you; AND WHEREAS, we have been given to understand that said Claim is still due and unpaid, and remains a lien against the said property; NOW, you are hereby notified to file your Affidavit of Defense to said Claim, if defense you have thereto, in the Office of the Prothonotary of our said Court, within twenty (20) days after the service of this Writ upon you. If no Affidavit of Defense is filed within said time, Judgment may be entered against you for the whole Claim, and the property described in the Claim be sold to recover the amount thereof. $ -56 co P a ram L 015 bur:: Co �t 0 �3 EAL) Q . 3PT t ROTHONOTARY r SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson o Sheriff -vZ x;ti t,, of Clur ther, cW -1°5 Jody S Smith '� x rr Chief Deputy can "'t Richard W Stewart r Richard h `„'~ m "v ; ACC ---I N) =r- Silver Spring Township Authority vs. Case Number Nedeljko Gunjak 2014-349 SHERIFF'S RETURN OF SERVICE 01/24/2014 04:03 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Writ of Scire Facias by"personally” handing a true copy to a person representing themselves to be the Defendant, to wit: Nedeljko Gunjak at 228 Hogestown Road, Silver Spring, Mechanicsburg, PA 17050. 1..., _ ! Witt_. J IE DIMAR 11-41FBEPUTY DIMAR 'U SHERIFF COST: $39.30 SO ANSWERS, January 27, 2014 RONNY R ANDERSON, SHERIFF u IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN r O CIVIL DIVISION �� s' y Gov, SILVER SPRING TOWNSHIP AUTHORITY, 5 WILLOW MILL PARK ROAD SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, vs. NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 PARCEL ID#38-21-0289-003 Defendant. I Hereby certify that the last known address of Defendant(s) is/are: 228 Ho �. town Road Mec� Aor �.s rg, ' �- 150 A torney for Plaintiff SYLVANIA C O/18` ., hT <• No.: 14-0349 CIVIL TERM TYPE OF PLEADING: PRAECIPE FOR DEFAULT JUDGMENT (Municipal Lien) FILED ON BEHALF OF: Silver Spring Township Authority, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire — PA ID #55650 Kathryn L. Mason, Esquire — PA ID #306779 JSDC LAW OFFICES P.O. Box 650 Hershey, PA 17033 (717) 533-3280 CowkA .5op8 afki 1 CL._ abq a5 "\2_:* 3)0(e,1 N)t, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, vs. NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 PARCEL ID# 38-21-0289-003 CIVIL DIVISION No.: 14-0349 Civil Term Defendant. PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR/MADAM: Please enter a default judgment in the above -captioned case in favor of Plaintiff and against Defendant, Nedeljko Gunjak, in the amount of $4,194.05, plus interest, penalties, and Quarterly bills after the 2nd Quarter 2014 billing, and additi e; al attorneys' fees and costs reasonable and actually incurred. Date: May 20, 2014 By: PAI.. 5650 Kathryn L. Mason, Esquire PA I. D. #306779 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, . s evned by the attached copies. Scott A ..D Tett -squire Sworn to and subscribed before me this 20th day of May, 2014. My Commission Expires: 1—_,— NOTARIAL SEAL CHRISTINE L SPURLOCK Notary Public HUMMELSTOWN BORO, DAUPHIN COUNTY My Commission Expires Feb 2, 2017 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 vs. NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 PARCEL ID# 38-21-0289-003 Plaintiff, Defendant. CIVIL DIVISION No.: 14-0349 Civil Term NOTICE OF ORDER, DECREE OR JUDGMENT TO: Nedeljko Gunjak ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on , 2014. ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $4,194.05 plus interest, penalties, and Quarterly bills after the 2nd Quarter 2014, plus additional attorneys' fees and costs reasonable and actually incurred and for foreclostne and e of Premises. Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, vs. NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 PARCEL ID# 38-21-0289-003 Defendant. IMPORTANT NOTICE TO: Nedeljko Gunjak 228 Hogestown Road Mechanicsburg, PA 17050 DATE OF NOTICE: February 14, 2014 CIVIL DIVISION No.: 13-7033 MLD No.: 14-0349 Civil Term YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, vs. NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 PARCEL ID# 38-21-0289-003 Defendant. . AVISO IMPORTANTE CIVIL DIVISION No.: 13-7033 MLD No.: 14-0349 Civil Term A. Nedeljko Gunjak FECHA DEL AVISO: February 14, 2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. DATE: NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 JSDC LA BY: S A. i ietterick, E''uire PA I.D. #55650 Kathryn L. Mason, Esquire PA I.D. #306779 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 FIRST CLASS U.S. MAIL, POSTAGE PREPAID (717) 533-3280 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY m C11 iribert OFFICE OF 14E. $KRIFF Silver Spring Township Authority vs. Nedeljko Gunjak Case Number 2014-349 SHERIFF'S RETURN OF SERVICE 01/24/2014 04:03 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Writ of Scire Facias by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Nedeljko Gunjak at 228 Hogestown Road, Silver Spring, Mechanicsburg, PA 17050. (WJ..t IE DIMAR -, PEPUTY SHERIFF COST: $39.30 SO ANSWERS, January 27, 2014 RONIN R ANDERSON, SHERIFF (c) CounlySuite Sheriff, Teleosoff. Department of Defense Manpower Data Center Results as of : May -19-2014 01:35:45 PM Status Report Pett to Servicemembers Civil Relief Act Last Name: GUNJAK First Name: NEDELJKO Middle Name: Active Duty Status As Of: May -19-2014 SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Status Service Component NA NA'r•.7 'ti..t'Y n , i, ;� _f _•_- Nd f \t , NA #J/ ti., f N.1 '. Y `,t --i . ,,,,,,,,,,,,,,t.,�. 'A", -. i 4,4 ,1}-,,./ _"t This response reflects the,indilduats�active. duty, status based-on',the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Status Service Component NA r--r ii ..'.,NA , 4S.,tt--/'- y .4 i �.,F:f\ -.3 .. A+S's i� NA This response reflects where the ind vidual left act "Ir.. uty'statusiwithin 367. days preceding the ActivelDuty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA '14'.:N.- A' n1.'^_. ' 1 `J ...,,,/ tit' ,,',/ t',/ NA A:\ •t,., ��.. � -<-�-- , r� .'s- -. This response reflects whether the individual or-his/herr unit has-received_eatly notification to report for active duty Upon searching the data banks of the Department of Defense Manpower -Data CeLT- et nter,'bdied on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Unifo dServices rmy, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: R9030F1 DPOCB720 IN THE COURT OF CSN PLEAS OF CUMBERLAND L'OUNT'Y, PENNSYLVANIA Silver Spring Township Authority v Nedeljko Gunjak CIVIL DIVISION File No. 14-0349 Civil Term (Plaintiff) (Defendant(s) TO THE PROTHONOTARY OF THE SAID COURT: : Amount Due . Interest from date of sale Atty's Comm Costs $ 4,194.05 to $ The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it -is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) See Exhibit "A" attached. rrw 73 _..r --C E) PRAECIPE FOR ATTACHMENT EXECUTION C Issue writ of attachment to the Sheriff of Cumberland Cour for interest and costs, as above, directing attachment against the above-named gar .ishee(s-)' for the following property (if real estate, supply six copies of the description; ---supply four copies of lengthy personalty list) C...) - C- CD-,= and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garn real estate of the defendant(s) described in the attached e DATE: May 20, 2014 V. GAF v.SOc< 11, Sbt, < < ZD . Sa Signature: Print Name: Address: James Smith Dietterick & Connelly LLP pendens against Scott A. Dietterick, Esquire P 0 Box 650, Hershey PA 17033 Attorney for: Plaintiff 4 6 . Telephone : (717) 533-3280 v'e� 3olaG2 Ci :nrpfy Court ID No . : .sem • 6. 55650 e=6 a LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, County of Cumberland, and Commonwealth of Pennsylvania, bounded and described in accordance with a survey made by William B. Whittock, Professional Engineer, dated February 27, 1963, as follows: BEGINNING at a point of intersection of the northeasterly right-of-way line of Pennsylvania State Highway Route No. 416 with the southeasterly right-of-way line of Township Road No. T-586; thence along the said southeasterly right-of-way line of Township Road No. T-586, North 44 degrees 24 minutes East, 210.13 feet to a point at lands now or formerly of Wesley W. Kaufman and Thelma I. Kaufman, his wife; thence along said lands, South 54 degrees 56 minutes East, 200.00 feet to a point; thence continuing by said Kaufmans' lands, South 44 degrees 24 minutes West, 200.00 feet to a point on the northeasterly right-of-way line of said Pennsylvania State Highway Route No. 416; thence along said right-of-way line, North 54 degrees 56 minutes West, 112.12 feet to a point on said lands; thence continuing along said right-of-way line, South 35 degrees 04 minutes West, 10.00 feet to a point on the same; thence still continuing by said right-of-way line, North 54 degrees 56 minutes West, 89.87 feet to a point at the place of BEGINNING. CONTAINING 0.94 acre. HAVING THEREON ERECTED a split level brick and aluminum dwelling known and numbered as 228 Hogestown Road, Mechanicsburg, Pennsylvania. BEING the same premises which Dena L. Zugzda, Widow, by her Deed dated December 19, 2007 and recorded on December 31, 2007 in the Office of the Recorder of Deeds for Cumberland County as Instrument Number 200747830, granted and conveyed unto Nedeljko Gunjak, single man. Parcel No.: 38-21-0289-003 Exhibit "A" IN THE COURT OF COMMON PLEAS OF 22 CUMBERLAND COUNTY, PENNSYLVANIA df �^ Pt p Pb <f�� SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION Y1-1(CNG AHiA 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 vs. NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 PARCEL ID# 38-21-0289-003 Plaintiff, Defendant. : No.: 14-0349 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Silver Spring Township Authority, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 228 Hogestown Road, Mechanicsburg, Pennsylvania 17050: 1. Name and Address of Owner(s) or Reputed Owner(s): NEDELJKO GUNJAK 228 Hogestown Road Mechanicsburg, PA 17050 2. Name and Address of Defendant(s) in the Judgment: NEDELJKO GUNJAK 228 Hogestown Road Mechanicsburg, PA 17050 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: SILVER SPRING TOWNSHIP AUTHORITY Plaintiff BOWMAN SALES & EQUIPMENT, INC. Bowman Trailer Leasing 10233 Governor Lane Williamsport, MD 21795 4. Name and Address of the last record holder of every mortgage of record: MERS AS NOMINEE FOR SUNTRUST MORTGAGE, INC. P.O. Box 2026 Flint, MI 48501 and c/o 901 Semmes Avenue Richmond, VA 23224 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: DEPARTMENT OF REVENUE COMMONWEALTH OF PA UNKNOWN SPOUSE OF NEDELJKO GUNJAK 7. Name and Address of every other person of whom any interest in the property which may be affected CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 228 Hogestown Road Mechanicsburg, PA 17050 the Plaintiff has knowledge who has by the sale: Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATED: May 20, 2014 BY: JSDC tw '1,41FIY - Sco A.N e terick, Esquire Pa. I.D. #55650 Kathryn L. Mason, Esquire Pa. I.D. #306779 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA `i;?:_c•RL /10 c h.74 OF cLicfQ,,,,,,::: vz:10,71--rn CIVIL DIVISION lh oFt„- SILVER SPRING TOWNSHIP AUTHORITY 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 vs. NEDELJKO GUMAK 228 HOGESTOWN ROAD MECHANICSBURG, PA. 17050 PARCEL ID# 38-21-0289-003 Plaintiff, Defendant. : No.: 14-0349 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Nedeljko Gunjak 228 Hogestown Road Mechanicsburg, PA 17050 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, September 3, 2014, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 228 Hogestown Road Mechanicsburg, Pennsylvania 17050 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 14-0349 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Nedeljko Gunjak A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 (800) 990-9108 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. DATED: May 20, 2014 BY: JSDC LA O , 7111111 S o A. Diettenc quire Pa. I.D. #55650 Kathryn L. Mason, Esquire Pa. I.D. #306779 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED and VIA PERSONAL SERVICE BY THE CUMBERLAND COUNTY SHERIFF LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, County of Cumberland, and Commonwealth of Pennsylvania, bounded and described in accordance with a survey made by William B. Whittock, Professional Engineer, dated February 27, 1963, as follows: BEGINNING at a point of intersection of the northeasterly right-of-way line of Pennsylvania State Highway Route No. 416 with the southeasterly right-of-way line of Township Road No. T-586; thence along the said southeasterly right-of-way line of Township Road No. T-586, North 44 degrees 24 minutes East, 210.13 feet to a point at lands now or formerly of Wesley W. Kaufman and Thelma I. Kaufman, his wife; thence along said lands, South 54 degrees 56 minutes East, 200.00 feet to a point; thence continuing by said Kaufmans' lands, South 44 degrees 24 minutes West, 200.00 feet to a point on the northeasterly right-of-way line of said Pennsylvania State Highway Route No. 416; thence along said right-of-way line, North 54 degrees 56 minutes West, 112.12 feet to a point on said lands; thence continuing along said right-of-way line, South 35 degrees 04 minutes West, 10.00 feet to a point on the same; thence still continuing by said right-of-way line, North 54 degrees 56 minutes West, 89.87 feet to a point at the place of BEGINNING. CONTAINING 0.94 acre. HAVING THEREON ERECTED a split level brick and aluminum dwelling known and numbered as 228 Hogestown Road, Mechanicsburg, Pennsylvania. BEING the same premises which Dena L. Zugzda, Widow, by her Deed dated December 19, 2007 and recorded on December 31, 2007 in the Office of the Recorder of Deeds for Cumberland County as Instrument Number 200747830, granted and conveyed unto Nedeljko Gunjak, single man. Parcel No.: 38-21-0289-003 Exhibit "A" THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net SILVER SPRING TOWNSHIP AUTHORITY Vs. NEDELJKO GUNJAK WRIT OF EXECUTION NO 14-349 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $4,194.05 Interest Atty's Comm: Atty Paid: $74m. 0 Plaintiff Paid: Date: 5/22/14 (Seal) L.L.: $.50 Due Prothy: $ 4f.SD Other Costs: kLaiL David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name: SCOTT A. DIETTERICK, ESQUIRE Address: JAMES SMITH DIETTER1CK & CONNELLY LLP P.O. BOX 650 HERSHEY, PA 17033 Attorney for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No. 55650 IN THE COURT OF COMMON PLEAS OF D-0*' Lp. THE PROTHONOTA: 2814 AUG 12 PH 2:08 CUMBERLAND COUNTY, PENNSYLVANIA CUMBERLAND COUNT PEN SYLVAN!A CIVIL DIVISION SILVER SPRING TOWNSHIP AUTHORITY 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 vs. NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 PARCEL ID# 38-21-0289-003 Plaintiff, Defendant. No.: 13-7033 MLD No.: 14-0349 Civil Term PRAECIPE TO SATISFY MUNICIPAL LIEN TO THE PROTHONOTARY: SIR/MADAM: Please mark the Municipal Lien filed at the above — captioned term and number satisfied. Date: August 7, 2014 JSDC LAW OFFICES By: Scott A. Dietterick, Esquire PA I.D. #55650 Kathryn L. Mason, Esquire PA I.D. #306779 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff kitv, �q SD�aC1�� 10.1 d(Loio pjf. 3oct-734, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 vs. NEDELJKO GUNJAK 228 HOGESTOWN ROAD MECHANICSBURG, PA 17050 PARCEL ID# 38-21-0289-003 Plaintiff, Defendant. : CERTIFICATE OF SERVICE CIVIL DIVISION No.: 13-7033 MLD No.: 14-0349 Civil Term The undersigned hereby certifies that a true and correct copy of the Praecipe to Satisfy Municipal Lien was served on the following this 7th day of August, 2014, via First Class U. S. Mail, Postage Pre -paid: Date: August 7, 2014 Nedeljko Gunjak 228 Hogestown Road Mechanicsburg, PA 17050 JSDC LAW OFFICES By: is\��11, !.L? Scott A. Dietterick, Esquire PA I.D. #55650 Kathryn L. Mason, Esquire PA I.D. #306779 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY TILED -OFFICE CIF HE PROTHONOTARY ZOi 4 AUG 29 PM 2: 0 I CUMBERLAND COUNTY PENNSYLVANIA oFFsCE or s ERIFF Silver Spring Township Authority vs. Nedeljko Gunjak Case Number 2014-349 SHERIFF'S RETURN OF SERVICE 06/23/2014 06:15 PM - Deputy Noah Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 228 Hogestown Road, Silver Spring - Township, Mechanicsburg, PA 17050, Cumberland County. 06/23/2014 06:15 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Nedeljko Gunjak at 228 Hogestown Road, Silver Spring, Mechanicsburg, PA 17050, Cumberland County. 07/18/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,001.30 August 28, 2014 (c) CourtySu a heriff. Teleosaff. Enc. SO ANSWERS, RON2-R ANDERSON, SHERIFF I/0 p ekh 31b4 3 4 On May 23, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Known and numbered as, 228 Hogestown Road, Mechanicsburg, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: May 23, 2014 80 :b V LZ OW NH v`d `h By: Real Estate Coordinator LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 No. 2014-349 Civil SILVER SPRING TOWNSHIP AUTHORITY vs. NEDELJKO GUNJAK Atty.: Scott Dietterick ALL THAT CERTAIN piece or par- cel ofland situate•in the Township of Silver Spring, County of Cumberland, and Commonwealth of Pennsylvania, bounded and described in accor- dance with a survey made by William B. Whitlock, Professional Engineer, dated February 27, 1963, as follows: BEGINNING at a point of intersec- tion of the northeasterly right-of-way line of Pennsylvania State Highway Route No. 416 with the southeasterly right-of-way line of . Township Road No. T-586; thence along the said southeasterly right-of-way line of Township Road No. T-586, North 44 degrees 24 minutes East, 210.13 feet to a point at lands now or formerly of Wesley W. Kaufman and Thelma I. Kaufman, his •wife; thence'along said lands, South 64 degrees 56 minutes East, 200.00 feet to a point; thence continuing by said Kaufinans' lands, South 44 degrees 24 minutes West, 200.00 feet to a point on the northeasterly right-of-way line of said Pennsylvania State Highway Route NO.4 16; thence along said right-of-way line, North 54 degrees 56 minutes West, 112.12 feet to a point on said lands; thence continuing along said right-of-way line, South 35 degrees 04 minutes West, 10.00 feet to a point on the same; thence still continuing by said right-of-way line, North 54 degrees 56 minutes West, 89.87 feet to a point at the place of BEGINNING. CONTAINING 0.94 acre. HAVING THEREON ERECTED a split level brick and aluminum dwelling known and numbered as 228 Hogestown Road, Mechanics- burg, Pennsylvania BEING the same premises which Dena L. Zugzda, Widow, by her Deed dated December. 19, 2007 and recorded on December 3I, 2007 in the Office of the Recorder of Deeds for Cumberland County as Instrument Number 200747830, granted and conveyed unto Nedeljko Gunjak, single man. Parcel No.: 38-21-0289-003. 1 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 11 and July 18, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this COMMONWEALTH OF PENNSYLVANIA 1 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 The Patriot -News Co. 1900 Patriot Drive Mechanicsburg, PA•17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriotNews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Amy Kotula, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2 14-349 Civil erm SIL SPRING T WNSHIP AUTHOR vs. NEDELJKO GUNJAK Atty: Scott Dletterick ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, County of Cumberland, and Commonwealth of Pennsylvania, bounded and described in accordance with a survey made by William B. Whitlock, Professional Engineer, dated February 27. 1963, as follows: BEGINNING at a point of intersection of the northeasterly right-of-way line of Pennsylvania State Highway Route No. 416 with the southeasterly right-of-way line of Township Road No. T-586; thence along the said southeasterly right-of- way line of Township Road No. T-586, North 44 degrees 24 minutes East, 210.13 feet to a point at lands now or formerly of Wesley W. Kaufinan and Thelma I. Kaufinan, his wife; thence along said larits; Sbeti 4 degrees 56 minutes East, 200.00 feet to a point; A Sworn to and This ad ran on the date(s) shown below: 07/13/14 07/20/14 07/27/14 .ubscribed before me this 20 day of August, 2014 A.D. tary Publi COMMONWEALTH OF P€NNSYkVANIA NOTARIAL SEAL Sheryl Marie Leggore, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES