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Home My WebLink About98-03463 I ~! ~ ,. I,,,,J. .... OJ '" 't1 :\:::1 ~! ] j ~! \.. u .1!c .~~'*ii;;r!," ~ '~':,\.:. "" ~.,\\ -tC; ..', ~' ". \ \ ) I I ! , I j i ; I I 1 j (1 -.1 I ~1 I .1 -..1 . ," -i " ') j ~l .~ 1"<)1 J .. ,I ...., ) :>-1 l'<'\! , ,I '-1 ~\ ] ~ ,:j' '.:' ~ J \ ! i ) I I tf. . \ I } ~ ) 1 I I l:~~: ,," --:>\ (:'." :, ,~~\ n: ll.. ~.' gv' \'~l . ..... "r, U '(',.../,'.., I . ......~,;o" ~ " " ~ '>- ,~ i g &; of:~ i..) ~ :> '-' , ....lil;:l~ ~=-o-:+- 8$~ e "C~-<C( !il"A.. !:l 'E ,f .0 ::l Vi ,:: E: 0'- "4- '" u~ + u~u-q;: G() ~l fjGf <r:f5 "'0 :IJ <it"" ~g I!.!<;: ;fii "'~ ~~ '" .,.~.~ ......~.......~;' (.. '. I ~:' t)N ~o -~ C1Jr-- 1-."'8..... ~:.a ..... '~ E-< 2: :,G 'E oil -c 0 3 "'ZoO u c.o'~ . => t:: .,gC\'" ",,~:r: l .:::> '" '" o - 'B r-... '" 00 o ,.., u 0":' .2:' @ c-r) t:: .:s::':: 5 ..O"~ r \ ~ .-. '-' ~ '0 ::1'~ @ 0 ", "i:..c " " 1:: " ..0:300 ,... 0'- C:u- ::l ;a u~u \ ".-. ,_ I ~.' :r '. (0') ',--, (/) \I.U ,_, "\'. '-.' I'. .'j I: p. r-J"~ (. "J ....; ...''''~ ..[J-;;:' , ,,\, / ~:.. .:/: ., ' .-' 4., . ---' .-.. .., r . ,',f, ,_,. c:: ~tJ 1.1, I . --. '. :::.. ."- -.J ;:0' tu -.::.: c:~ f- e:' Z 1,\ d' \ cr \ ')- ::. -:t <.\ -- ;.. l> ,...s;: ""t ct. ..f -r q:- .. 't 't " 00 - '" ... 1I' 0 I1J i1 .J -I H U,O a: za:a: I1J <(11J - ;:::;q 03Cl ..,J'" a:a:z .~ I1J ow !jW'J I1JU,Ul ,., 0 ':;IQ 0:00 ~ :1Jf- Of-f- 0 ,...2- ClI1JZ - \ ca: a:.Ja: !"-:,j <(OJ:J -If- 3<(1- UJ a:ZI1J n: O:Ja: U, 0 OJ 0 Ul Z H I1J a: " 0; , I. 0; 0; 0' 0 0; I '.~ ,.. 1 , ..' In 'l'ho Court Of Common Ploas Of CUrnbOl"lilnd County I't"othonoLary's OfCico COUR'1'1I0lJSI'; Carlislo, Pa 17013 Civi I AcUon No.: 1998-03463 U". !'./ ., I) 1\: , KREISER CARL RICHARD 1908 NORTH THIRD STREET HARRISBURG PA 17102 KREISER FLORA M ETC Plaintiff ** VERSUS ** KREISER CARL RICHARD Defendant You are hereby notified that a Decree in Divorce was entered in the above captioned case on September 15, 1999. This letter should not be used in place of the actual Decree. If you desire a certified copy of this Decree, you can obtain the same by coming into our office. Please bring this letter with you. The fee is ;y.a? C'..d p, M7 I f request is made by mail, please enclose :;:?tJa for the certified copy of Decree. Also, do not forget to indicate Civil Action No. on your request. .,~"'" .- . ' :.; ',', ..;.- .... 0...:' \:/-. .,~. ....' " ~ (")' H I'd trJ ... o ...... 1 rn .3: .H ... .~ (") o .~.' ~ t-' ~ H () ::I: ~ t:J ~. H rn trJ t:J ~. 11> . HI 11> :l 0. JlJ :l rt "J 1:1 O. . t:J ~..' ~ '" rn Cll ::I::3: trJ , ~ w '-~ ol'> <1 tIl ,. . I'd 'I-' '.JlJ "'-. . ~.....' rl': ..,. .'HI ...-Hl' .....,., .,;,t' . FLORA M. KREISER, alkla FLORA M. DASHER, IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs, No. f J '- 3I..JW {l C o.,'L L CARL RICHARD KREISER, Defendant CIVIL ACTION - LAW NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A jUdgment may also be entered agninst you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for thc divorce is indignities or irretrievahle breakdown of the marriage, you may request marriage counseling. A list of malTiage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania, 17013-3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNUL- MENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU ISHUULU 'fAKE 'lHIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO 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 A venue Carlisle, Petmsylvania 17013 7/7' J ~f"3(&(o rLORA M. KREISER, alkla FLORA M. DASHER, IN TIlE COURT or COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs, No, qp-j"-lIoJ Cu/'[ ~i7 CARL RICHARD KREISER, Defendant, CIVIL ACTION _ LA W COMPLAINT I. Plaintiff is Flora M. Kreiser, a/kJa Flora M. Dasher, who currently resides at 2128 Market Street, Camp Hill, Cumberland County, Pennsylvania, 1701 I since Sept. 1995. Plaintiffs Social Seeurity No. is 174-58-7520. 2. Defendant is Car! Richard Kreise:-, whese !nst known residence is 1908 North Third Street, Harrisburg, Dauphin County, Pennsylvania, 17102. Defendant's Social Security No. is 178-50-3481. 3. The Plaintiff has been bona fide resident of the Commonwealth of Pennsyl- vania for at least six months immediately previous to the filing of this Complaint. Maryland. 4. The Plaintiff and Delendanr were malTied Aprii 18, 1992 ill Hagersrown, 5. There have been no prior actions of divorce or annulment of marriage between the parties. 6. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 7, The marriage is irretrievably broken, 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff requests the courl to enter a decree of divorce. I verify that the statements made in this Complaint arc true and corrcet. understand that false statements herein arc made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsIVorn fa!s:fications to m'rhoritjp'~. - :',' I II . '<'(l' 1G\.. 7V 1<','-\ (I~ ,oJ Vl'--. FLORA M. KREISER ~~[~~t~.~ls~ ,~1~ IRA II. WEINSTOCK, P.C. 800 North Second Street Harrisburg. P A 17102 Phone: 717-238-1657 By:. ,) ')'.. /; ".\en (, 1-1. ( (.>..OA.'I I.) tcd.,.f. IRA H. WEINSTOCK ._...h<.......' ---- " , \ 'I ~ J " " \, ,- :;:d "', ~)> :,; /"I"~ ' ~ , .:;" '''eg' < . , ,~, " . < - j).,;~}:>~:):,.<~,~,,:~,'t'I' !;-... ;;:':~T~ ~,~ z ",~" ;;;r: ,: ~ " 8 en Sl " '..I\), ... 'v> ,o-l n ,,;,.;;,,~ <:;10 I: ::q7~{~i.1. },:.;::;:::_~:_~_:<'.': :,' 0') : .,-. '''~''->''-J CD,,',.- ,""1 ' ,,,.,,,",'111...' ;:j ", ' ,.;' :r;~t~~~J}:\:;?-'!,~f:2,:,:--. . ..' '," :-c \i:~ri?;y:.~;:{ p ~:4~ I1;lH t:Jl1;ltrJ ~tJil1;l H t:J:liZ: HO t<...rn HHC:: Ci'lOl'd gJiZ:;g (")11;l~ ' trJ~... o 11;l'>il H g~ 2iH Ci'l2: 1 "j, n ~, 1:1 ~ H (") ::I: ~ t:J < ~ tIl t<J H Ul tl t<J Cll '::<1 Hl . 11> ~ 0. JlJ ::s .rt , '. ~~, 00 ~~ :3::3: , , t:l ~, ~::<1 rn t<J' ,tll H ,trJ rn ~t<J ..<~ . '" I-' JlJ, ..,. ~ rt' ..,." H, HI, ' ,"; JlJ , ........ ,;.;', "', JlJ ' ~;i,. nZ("),H '~~,S.~ H"Iii... l:1\OtrJ,11l ,'oo~trJ ~, ,t"', ,(");I,~(") .....,:;::0 ',HWt:Jc:l 'O.;..",'.~ "~''''(").... ""w,O,'.. .;I',"C::O ,','"'(") 2:":1 ,H"""':;' ',2:<.><'(") (..,.... :,0 t:f,1-' ',?:~'~~ H';":"":;:: <:,...'trJ'Q ;.Q'l1>:2:'iZ: ~l2:" \~itiil Pursuant to Pa.R.C.P. I 920.42(e)(2): (c) Notice of intention to request entry of divorce decree shall not be required prior to entry of a divorce decree (2) under!i 3301(<1) where the court finds that no appearance has been entered on defendant's behalf and that defendant cannot be located after diligent search. Inasmuch as Plaintiff could not locate Defendant and service of process of the Complaint and Plaintiff's Affidavit was made through publication, Plaintiff believes she will not be able to locate Defendant to serve Defendant with the Notice of Intention to Request Entry of the Divorce Decree on the Defendant. WHEREFORE, Plaintiff respectfully requests this Honorable Court grant an Order waiving service of the Notice of Intention to Request Entry of Divorce Decree on the Defendant and allowing Plaintiff to proceed with filing the necessary documents to finalize the divorce in this action, Respectfully Submitted, IRA H. WEINSTOCK, P,C. 800 North Second Street Harrisburg, P A 17102 Phone: 717-238-1657 By: Is ~()... {~. uJ~h,)fuc.L. IRA H. WEINSTOCK - 3 - .~c.::~""~:::~~ FLORA M, KREISER, a/k/a FLORA M. DASHER : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, CARL RIeI-IARD KREISER NO. 98-3463 CIVIL TERM AND NOW, this ORDER OF COURT ,;J. i~ day of JUL Y, 1999, upon review of the Plaintiffs Motion For Finding Of Due Diligencc, Plaintiffis directcd to file a brief in support of her position that a divorce decree may be entered without notice to the Defendant where the only service of the pending action and Plaintiffs affidavit under Section 3301(d) is by publication. { , , 11 i/1 I.: !'. I ' il\~:, f ,';;;. ~ ~ I}':!' I' :i Iri ,{ "1'" 1,""'- 1\,'1"" [{t/i~: fj,i.- I;, By the Court, Edward E. Guido, J. Ira H. Weinstock, Esquire 800 North Second Street Harrisburg, Pa. 17102 ~<rt') r>?~u..(!L"C 7/.l. If/ q 1 . o .-So 1'. :sld '~'.~, ' .:::, , , 0;]; , <..)~? r.)~ .~s: ::.t-O) , ...J?: r.r:,z UJIf) . <go.; .< ' ''':::'l' ',&, .,... it: <::l (\1, "~,. :.::: -- ~ ~ t'" ":I H ~ t:J H ,,", ~ (') 0 tI: 0, H ~ <: z' ... t:J tIl ~ 1;J ,0 trJ 'lij H Ul trJ t:J !:O ,'". ro . HI ,l1> ::l 0. JlJ ::l rt . ":1":1 t"'1:1 00 ~ ~, \0 .' a new address of P. O. Box 580. New Cumberland, Pennsylvania, 17070. (d) An attempt to serve the Complaint and Plaintiff's Affidavit was made by muiling them first class regular mail aud certified, restricted delivery at P. O. Box 580, New Cumberland, Pennsylvania, 17070 on July 9, 1998. Both envelopes containing the Complaint and Plaintiff's Affidavit were returned and marked "No Forward Order on File, Unable to Forward, Return to Sender" and "Attempted Not Known". (e) No listing for the Defendant appeared in the local telephone directory. (I) A call was made to Directory Assistance in the 717 area code and the operator indicated there was a listing for a "Carl R. Kreiser" in New Bloomfield, Pennsylvania. This number tumed out to be the Defendant's parents who stated they have not heard from nor seen their son in years. (g) On July 9, 1998, Plaintiff sent a Request For Change of Address to the Postmaster in New Cumberland, Pennsylvania. The Postmaster returned the request indicating "Not known at address given," (h) On September 23, 1998, Plaintiff sent another Request for Change of Address to the Postmaster in Harrisburg, Pennsylvania. The Postmaster returned the request indicating "No change of address order on file". (i) Another attempt to serve the Complaint and Plaintiff's Affidavit was made by mailing them first class regular mail and certified, restricted delivery at 1908 North Third Street, Han-isburg, Pennsylvania, ] 7102, on October 7, 1998. Both envelopes containing the Complaint and Plaintiff's Affidavit were returned and marked "Forwarding Order Expired" and "Undeliverable as Addressed-Forwarding Order Expired". 0) In November 1998 and again in February 1999, Plaintiff contacted a Stuart Wolnak from U. S. Tracing. U. S. Tracing was unable to provide any helpful information in trying to locate the Defendant. (k) A name search in the state of Pennsylvania was conducted through People Finder via the Internet. The search located only one Carl R. Kreiser located in New Bloomfield, Pennsylvania. The listing for Carl R. Kreiser located in New Bloomfield, Pennsylvania is the father of the Defendant. After contacting the Kreiser residence in New Bloomfield, Pennsylvania, Mrs. Kreiser stated that she nor her husband has seen or heard from their son (the Defendant) in years, (I) A name search in the state of Florida was conducted through People Finder via the Internet. The search states "No entries match your query." (m) On March 2, 1999, a letter was sent to the Department of Highway Safety and Motor Vehicles in Tallahassee, Florida requesting car registration information coneeming the Defendant. The Department of Highway Safety and Motor Vehicles returned the letter with a notation stating "Not Registered". (n) On March 2, 1999, a letter was sent to an acquaintance of the Defendant asking for any infonnation she would be willing to share regarding the whereabouts of the Defendant. To date, the letter was not returned nor was a response received. 2. The allegations as stated in the foregoing Motion for Finding of Due Diligence are true and correct to the best of my knowledge, infonnation and belief. "'~ ::1o'!, ClZ .O,,~ (",\>j .\.:;.~ ':'.~(p ..;> , "\/,, \b~ 0.}\.1- .~,. :=5'. <.J ~ '0 ,C:j ':O:C ~, - - ..,- :;.:> ..., CT' CT' ,',' ',:: . ...... ,', ':,; ':;\:I .:: ..~ r:" '_' 'too.... '-,; <.:J: :"':" ,:~~, ',it 'I !:~, ~ ':{t'\it'I'~~ ~ ~2' ~.' " ,':::1 ,i!:'Zi5tn", ,', ';:l"Oo-j'" ,':~ ':~ S '0 8 );;', 8i,:,J -l: ,0' ',"I, !:~ ',r: ,',' .. ,', ". "tI', ,,;,:,:;'~/'{~:/::::: .1,' -"'::C'.~~):.<:"": ..-,', ~ ":I H ~ <: H ... o "il rn ~ H C"l trJ ~ t" ~ H () 0:1 ~ tl 1:3 tll H t:J Ul CD tll Hl :c CD . ::l 0. JlJ ::l rt :.,):-.;- < tIl ":I Ooij' 1:11:1 00 ~~,' :3::3: , " ~1:3 rn trJ ., O:IH ' 'tll Ul ' :C,trJ ~' ~ '~ 'tl I-' JlJ ..,. , ::l 'rl' ..,. HI HI ",;: ,C"lZn'H H OO,Z <: ' ',':3: ' . H:bl,i-3 1:1:\0 trJ::::I: , Cll':C trJ ,~,'~':8 ",>'"z'o ,H w't:J,O Ool'>,'''',~ Z'''':C"l,8 " w.o",'.;" I'~'O 'H:,8~ z..:: 1<:C"l ._/::-:,,;,'.....';...:,0, 't:J. "~ o~;~Ji . ',' \' ~ ~ en .':~'c.;~.\ ..),~' PROOF OF PUBLICATION . State of Pennsylvania, County of Cumberland, Sherry Clifford, Classified Advertising Manager of THE SENTINEL, of the County and Stale aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in lhe Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which dale THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dales, viz Copy of Notice of Publication ", :01:, tis' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSVLVANIA NO:98.3463 . IN DIVORCE ,11 FLORA M, KREISER, alkla FLORA M. DASHER, Plainlill '-l,;P VS. . ,.i~' _ CARL RICHARD KREISER: Def.ndanr----- ' .lIk liQIlg;IQ llHlililHlliQ Ql.AlM~ :,,00 YOU HAVE BEEN SUED IN COURT. II you wish 10 delend .('1 .the claims set forth In lhe following pages, you musllake . ,prompt acllon. You are warned that \I you laU 10 do 50, the case -:.';mayproceedwilhoUlyoUandadecreeofdlvorceorennulmenl riant further deposes that he is not interested in b, may be entered, against you by the Court. A Judg'!lenl may also '.rb,b..nl.redagatnSIYOU'o'a~r.olherclalmo"e"efreqUeSled ~ subJ'ect matter of the aforesaid notice or ; eq In these papers_by IryePlalnll1 . YOIJ ",ay IOSl;lrnOf)ey.orproper.. ... ;olly orolh~r.righl$ Impo.anllo you,Includln9 CUSlody 0' '. d hi' . omvisitaflon 01 your chUdren, , " ".,,,...' vertlsement, an t at all al egatlons In the ':;r~ -When the ground f01 the divorce is indignities or Irretrievable ,.;; breakdown.fthemarriag.,youmay'eqoestme~l.ge ,'egoing statement as to time, place and character !. o~CO!J':\!iQI!I'\9. A list of marriage counselors i~ available in the Of. ,0 ,.Ile..1 m~, ~mlfloQ,olaoy, C'mbe~and Counly ,Counhouse, 1 "publication are true ,~Coluthouse Square, Carlisle, Pennsylvania; 17013.3387. . ".t IF YOU DO NOTFILE A CLAIM FOR AUMONV. DIVISION ,~ "OF PflOPERTY, ~AWVER'S FEES OR EXPENSES BEFORE' , ,t~~.!lJ~~~e&.M_, '"I!cIff~TJS~8t~TE&Y9g~~T?'1 '~~fflJ, pJjjj)!J'j ,1HlsJIlER:rO ~OUR U;WVER AT '__ 01<. VOtl' UIAVI,,\I.AWYEROR CANNOT, '"AFFORD ONEo'GO Tll.OR TEl-EPHONE THE, OFFICE SET ,Wf,ORTH BELO\V,TO FIIjO OUTWHW YOV:,C,~GET,'" ~. -':LEGALHELP., '.'-1 ,_.....Ii. .. ~-;" ~.' '.. .,,~t:,~'~Cum~erland County BS'tAssoClatlon ,,,,.<,t.~ :1~... :-:2.lIberty Avenu~, 9MisIB,'P,elJnsylvanla ',17013, /, "1 : "e;.Phone,717.249.2166 ,.,,', " , ,.",' " .-"" ,,',,' ~IQl)!SDEFENDANT' : j;:lm yol! wlsri~o<l.ny any Ollh. slalements S.llorth hi Ihls Alii. I "(;,Ctavlt, you must file a Counter.Allidavit wlthllJ 20 days alter this ' r~',:~~,,~I~I~has be~n serV~d on yo ",or Ih~ s~alement will be ~' orn to and subscribed before me this 11 th ,'i~'::' 'PLAINtl~F'SAFi'IMIiITUNbER of June 19 99 )i',' ,', SECTIONWll\QEIIl&DIVORCEl<Qf.H; I , .. "':_~,,_1;.The p~.'l!e~,to.It:'J.s.aCllon sepa!<!1,ed in F:ebruary 1993 and I .' '.have:contmuei:l,1o live separate and apart for a penod 01 at 'J~le'a5tlWO yoars::~!.. :',' ;", ~.:;~, 1:he'marr!llge I~ Irretrievably broken. ", . .~' :3.1 understahd that 1 may rose rlghts concerning alimony, ,:' division of property, lawyer's lees or expenses III do not claim :~t them before a ~jvorce Is granled. " "'",;:\~f"jYjl!>!ll!lie ~,"!Jl, '!!!lnls made I nthl,SAlfldavua r. Iru, e and,' '_ 111i,XJ . C j\Uh~el'$taild U~t false stalementshereln,are made " :OI$.W l:l,lllJl1a~UIeS'O,I\16 Pa,C.s;~904 retaling 10" ;".... ,,. unsworn falslficalfon 10 au norllles. ."0.0100:6116/98." ,_ Is/Flora M. Kreiser . 'DateO~6118!8B,::' '''. 's/Flo'....!olc~ J commission expires: June 4, 1999 ~~?,~~d June 11, 1999 ~o'~ Notary Public Notarial Seal , Shirley 0, Oumin. Nolary Public Carliste Bore, Cumberland Counly My'Gommisslon Expires Aug, 9, 1999 Member, Pennsylvani;l A<sO<l;otlon 01 NOi;lIle$ , '.' '.~ "":"."7:':;' . ":"':~'--:':':~~~B_ {~;:.-. EXHIBIT 'r: r "An ,'''';'''.''',.-_M; i;V; , ,',',' 1- l'4l; . ,"":,",;:.;'~M " . :~~,~._'~>"':;_<~~;:{~0;1~~S~: ~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA: 55. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Joumal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Joumal, 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 ofthe said Cumberland Law Journal on the following dates, Viz JUNE I 1. 1999 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 ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are R~I!~~ SWORN TO AND SUBSCRIBED before me this I I day of JUNE. 1999 SEAL lOl6 e, SNYDeR, Notary Pvbll: Carlisle Bon>, Cumborland County PA _~:~~O<l Expiro. March 5, 2001 .... on three separate occasions via regular first class mail und certi fied, restricted delivery at two different addresses; (2) by contacting the Postmastcr in Harrisburg, Pennsylvania and New Cumberland, Pennsylvania requesting new uddress information; (3) by contacting Directory Assistance; (4) by contacting U.S. Tracing in an attempt to locate the Defendant; (5) by conducting a name search in the states of Pennsylvania and Florida through People Finder via the Internet; (6) by contacting the Motor Vehicle Department in Florida regarding any vehicles registered to the Defendant; and (7) by sending a letter to an acquaintance regarding the whereabouts of the Defendant. All efforts have been llllsuecessful. Attached as Exhibit "A" is a Return of No Service filed with the Prothonotary detailing Plaintiffs efforts at service, 5, An attempt to serve the Complaint and Plaintiffs Affidavit by mailing them first class regular mail and certified, restricted delivery at 1908 North Third Street, Harrisburg, Pennsylvania, 17102 was made on June 23, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "No Forward Order on File, Unable to Forward, Return to Sender" and "Undeliverable as Addressed-Forwarding Order Expired". See Exhibit "B" attached hereto. 6. On July 7, 1998, Plaintiff sent a Request For Change of Address to the Postmaster in Harrisburg, Pennsylvania. The Postmaster returned the request indicating a new address of p, O. Box 580, New Cumberland, Pennsylvania, 17070, See Exhibit "C" attached hereto. 7. An attempt to serve the Complaint and Plaintiffs Affidavit by mailing them tirst class regular mail and certified, restricted delivery at P. O. Box 580, New - 2 - Cumberland, Pennsylvania, 17070 was made on July 9, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "No Forward Order on File, Unable to Forward, Return to Sender" and "Attempted Not Known". See Exhibit "D" attached hereto, 8. No listing for the Defendant appeared in the local telephone direetory. 9. A call was made to Directory Assistance in the 717 area code and the operator indicated there was a listing for a "Carl R. Kreiser" in New Bloomfield, Pennsylvania. This number turned out to be the Defendant's parents who stated they have not heard from nor seen their son in years. 10. On July 9, 1998, Plaintiff sent a Request For Change of Address to the Postmaster in New Cumberland, Pennsylvania. The Postmaster returned the request indicating "Not known at address given." See Exhibit "E" attached hereto. II. On September 23, 1998, Plaintiff sent another Request for Change of Address to the Postmaster in Harrisburg, Pennsylvania. The Postmaster retumed the request indicating "No change of address order on file". See Exhibit "F" attached hereto. 12. Another attempt to serve the Complaint and Plaintiffs Affidavit by mailing them first class regular mail and certified, restricted delivery at 1908 North Third Street, Harrisburg, Pennsylvania, 17102, was made on October 7, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "Forwarding Order Expired" and "Undeliverable as Addressed-Forwarding Order Expired". See Exhibit "G" attached hereto, 13, In November 1998 and again in February 1999, Plaintiff contacted a - 3 - . ...._...~.," Stuart Wolnak from U, S. Tracing. U. S, Tracing was unable to provide any helpful information in trying to locate the Defendant. 14. A name senrch in the state of Pennsylvania wns conducted through People Finder via the Interne!. See Exhibit "1-1" attached hereto. The search located only one Carl R. Kreiser located in New Bloomfield, Pennsylvanin. The listing for Carl R. Kreiser located in New Bloomfield, Pennsylvania is the father of the Defendant. Afier contacting the Kreiser residence in New Bloomfield, Pennsylvania, Mrs. Kreiser stated that she nor her husband has seen or heard from their son (the Defendant) in years. IS. A name search in the state of Florida was conducted through People Finder via the Internet. See Exhibit "(" attached hereto. The search states "No entries match your query." 16. On March 2, 1999, a letter was sent to the Department of Highway Safety and Motor Vehicles in Tallahassee, Florida requesting car registration information concerning the Defendant. See Exhibit "J" attached hereto, The Department of Highway Safety and Motor Vehicles retumed the letter with a notation stating "Not Registered". 17, On March 2, 1999, a letter was sent to an acquaintance of the Defendant asking for any information she would be willing to share regarding the whereabouts of the Defendant. See Exhibit "K" attached hereto. To date, the letter was not retumed nor was a response received. 18. To the best of Plaintiffs knowledge, information and belief, the address of 1908 North Third Street, Harrisburg, Pennsylvania, 17102 or P. O. Box 580, New Cumberland, Pennsylvania, 17070, is the last known mailing address of Defendant. - 4 - 19. Plainliff has made a good faith effort to locate and serve Defendant, but has been unsuccessllil. 20. Plainti ff believes that Defendant is intentionally absenting himscl I' from his county or concealing his whereabouts in this county in order to avoid service of process in this action, 21. Unless the Court allows service of process by way of publication, Plaintiff will be unable to maintain this action and injustice will result. WHEREFORE, the Plaintiff requests the court enter a special order directing service of the Complaint and Plaintifrs Affidavit on Defendant by publication. Respectfully Submitted, IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, PA 17102 Phone: 717-238-1657 By: c'\ ,~--------~ ;/ C) "--<---)LL IRA H. WEINSTOCK - 5 - a new address of P. O. Box 580, New Cumberland, Pcnnsylvania, 17070. (d) An attempt to serve the Complaint and Plaintirrs Affidavit by mailing them first class regular mail and certified, rcstricted delivery at p, O. Box 580, New Cumberland, Pennsylvania, 17070 was made on July 9, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "No Forward Order on File, Unable to Forward, Return to Sender" and "Attempted Not Known". (e) Looking in the local telephone directory. (f) Calling Directory Assistance in the 717 area code. The only listing they had was for a "Carl R. Kreiser" in New Bloomfield, Pennsylvania. This number tUl')1ed out to be the Defendant's parents who stated they have not heard from nor seen their son in years. (g) On July 9, 1998, Plaintiff sent a Request For Change of Address to the Postmaster in New Cumberland, Pennsylvania. The Postmaster retumed the request indicating "Not known at address given." (h) On September 23, 1998, Plaintiff sent another Request for Change of Address to the Postmaster in Harrisburg, Pennsylvania. The Postmaster returned the request indicating "No change of address order on file". (i) Another attempt to serve the Complaint and Plaintiffs Affidavit by mailing them first class regular mail and certified, restricted delivery at 1908 North Third Stieet, Harrisburg, Pennsylvania, 17102, was made on October 7, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "Forwarding Order Expired" and "Undeliverable as Addressed-Forwarding Order Expired". - 2 - 0) In November 1998 and again in February 1999, Plaintiff contacted a Stuart Wolnak from U. S. Tracing. U. S. Tracing was unable to provide any helpful information in trying to locate the Defendant. (k) A name search in the Slate of Pennsylvania was conducted through People Finder via the Internet. The search located only one Carl R. Kreiser located in New Bloomfield, Pennsylvania. The listing for Carl R. Kreiser located in New Bloomfield, Pennsylvania is the father of the Defendant. After contacting the Kreiser residence in New Bloomfield, Pennsylvania, Mrs. Kreiser stated that she nor her husband has seen or heard from their son (the Defendant) in years. (I) A name search in the State of Florida was conducted through People Finder via the Internet. The search revealed no one lives in the State of Florida by the name of Carl Kreiser. (m) A letter was sent to the Motor Vehicles Department in Florida requesting information regarding any vehicles registered to the Defendant in the State of Florida. (n) A letter was sent to an acquaintance of the Defendant regarding the whereabouts of the Defendant. To date, this letter has not been returned nor has a response been received. - 3 - i i, u) ..N..,. .-~--M::--- .... 0: ~: ~4: i'"),,' ?.)~ :'....~~ ':~~ -'.cll ":17- ;j-("Z t~1 ~iJ filL).. ~' - ~'I N ~ :l: 0'\ 0" -'-,,,.- " -\1,".,':.;'" ,'., t;~?;;::,?;....,.: · ..'~. , ' (",I""....' ..,', ~ ',' ~gi:{L;~;'l,.,,(~ ~.'" i i~~;f.f;;i:!:i:i .. ;f;~(~;r,P,l~.~ ~ ",..,. e S.... 3 'J" "'1\)" m n'll ;\;~jlP i: ~', ',' '0 1:, 1'1~'~~~:: a;',>,'">1 .:'0, ,\ ',,-.:; l.!.~~i~,:,~,.,.~ '?~, :~.-' .;_;..'_L~:>" ::;;, ",".. ,"',i'" .,'.' " " -:~.,,'., ,:...,-',-, tr- , .. ,'f.'" 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"." ,,' '.,' ATTACHMENT HZ Postmaster H"((I,lJ"r~ PA, 1-/101 City, Slllt~, ZIP Code Date: "/1/ ';1 Re'lu~t for Chlln~e of Addrl."is or Do,holder Infonlllllion Nt'Cded for Service of Lt'l:lIl Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: (~qr( (( ;,hord i< (t;',SI.'I Address: ICIC>~ 1\l<'lH Il,;, 1 S-t., I (HI;' h ,/, .-'/1, 111,,).. NOTE: The name and last knolloTl address are required for ch ge of address information. The name. if known, and post office box address are required for boxholder information. The following information is provided in accordance witb 39 CFR 265,6(d)(6)(1I). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance wilh 39CFR 2G~.G(J)(1) illJJ (2) and ~(j;rcspoiidi::g Aclmini:;tnlti',,~ S:.:ppcrt !o.fn.."':u::! 3S2.4t!~l ~m! b. I. Cap city of requester (e.g., process server, attorney, party representing himself): ~ '" l. 2. Statute or reg I tion that empowers me to serve process (not required when requester is an allorney ur a party acting pro se - except a corporation acting pro se must cite statute): 3, The names of all known parties to the litigation: ('jcl/o.. IY\, Kreiwr \J.o. Cc.,'1 j;:, , hn;-rl h'rv:icc 4. The court in which the case has been or will be heard: Clunlwr/ll/\r.\ CC_u.:l~11 CC:UIt c;!, (;""1/Y1(~1 Plr:c"s~ 5. The docket or other identifying number if one has been issued: No, qy--1,<!-{P-z, ('ill, f 6. The capacity in which this individual is to be served (e.g. defendant or witness): rsA't'-lIdn /\ +. WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10.000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 D,S.C. SECTION 100!). 1 certify that the above information is tme and that the address information is needed and will be used soldy for service of legal process in connection with actual or prospective litigation. J)lo- uJ.r..u,'l/:dc,h... 8Cb /oJ, SLCc~,<.~ y( , Signature Address =rr,,,- Wf"flS10r:1. Printed Name 1'/ ,~f r'lsbLvq I f:J Il/6:J. City, State~ZIP Code _ No change of address order on file. _ Not known at address given. _ Moved, left no forwarding address, No such address FOR POST OFFICE USE ONLY NEW ADDRESS or BOXHOLDER'S NAMJi and STREET ADDRESS & 8'7< 5FIJ J.; t:w C- v f'- f3 fi-Ol-..o POSTMARK /2. 17070 EXHIBIT lie" ~ "0'7 . ~ 0:" . n . i:: to'" 3 ::!. cr ~ ^ '" n .... :D 0; ;:l" fTJ OJ " .... H P- o.. Z UI 0 0> "0 0 >- - "11 :Deo :D , fTJZ:D fTJ -D'~ -lJ" eOJ:O C'I :Dr:D :Uo 2fTJO Z-J 0 - -1-10 -lJlJ OO:D 00 0 c c.n-Ilm ()lo{j fTJO); m 2:D 2>- O~O 02 - fTJ:OZ fTJ :D:D :D 0"11 H >- r -J fTJ 0 - -J "- >- >- - "- .lJ (ll :.' ~ 11 ~ ~ ~ c . ~ Z .... flinUl ~~ t ~~ ~ ... . ~ S 01 Z ~ ~ 7. - (Jl ;J ~ c 8 .., Cl ~ Ul 0 '" ~ ~ n III ~~ t: " :0 c , ... ~ o r~ 9=Do~ri' :z.:? ~ C':' '~- cn002-i' Ccncnri-I. ~CC,.....!!l;" _!(j......b~~ ~ !J :r 'i :;; '.: , ' '\:, ~2cnr=;;n:i;" : -C-IOO: -j ~ .:u'-1_; ,):. -- 'r'1l ;<-. ~', D rtl....', ~'r. ,- 'I -~ ~ -, ,} -~ . i :(~" ~:~: '/ " \I:..~y, 'so \ I?' ~ "~'.~ c-. , ,! 'j I ~ AITACHMENT 112 PostltUlster tlr,(,,'bu(Q~ PA, ,'JiGI City, Stule, Z I' Code Date: '\ . ,:P, .') ~ RellUe'it for ChaJll:e of Addr~~ or Boxholder lufonnlltion Nl'Cded for Service of Ll'l:ul Process Please tumish the new address or the name and street address (if a boxholder) for the following: Name: : d,(\,- I Address: 0"'''-' ( .rr,-b,'o '/-I. A,). NOTE: The name and last known address are required ~ change of address information, The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(II). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(I) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himsel!): 1-\ -\16 r" t~ 2. Statute or regulati n that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): 3, The names of all known parties to tbe litwation: , fiCfC_ N\, \(.(tls,el' Ii::', ('MI /::"c.h.cvd k\-j>J~e."" 4. The court in wbich the case has been or will be heard: u..."b,.ru. CC"~'t CJr 'YV\M" f! l-c.c'5~ 5. The docket or otber ide tifying numb 'r if one has been issued: 1\.\0, C)S( - ?'~I{, ~ (io/; I 6. The capacj;, in which this individual is to be served (e.g. defendant or witness): UF nJ<VI t- WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS. OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. ~Lc..lL"'-.:.vwtccL Signature ~OD 1\}>:>I+\-- 'SQ.\:.,~ S'i Address :Ln">, (t)'Tifldnek Printed Name H cun sbuJ~ ,PA. n 1l:l;2. City, Stat, ZIP Code XNo change of address order on file. _ Not known at address given. _ Moved. left no forwarding address, No such address FOR POST OFFICE USE ONLY NEW ADDRESS or BOXHOLDER'S NAME and STREET ADDRESS POSTMARK EXHIBIT lip" II~II ,LHIIIIXa ~~"7"CE FI'FIFi ED:'" --" .'. \ t.. . Z 571 384 913 . ~ .' . " . ',' "'MAIL'" .,;' , '. , ,\ : :.;,: .'! ,,"",'.f' 'U %1 1.1'1\ ~ 3 DJL'QJOllJf!UJlm,1 (,.) SOOj 'i' olil'lSOd 111101 ~ o 55.JJ!>pv 5,\lij~Jppv ~ 'ill~a i.. 'UlOlV;\ 01 WMat/S IdJJ:)J!;j umlJU ~ P\lIOMIi/(] OII!Q 'i' 1U0t1M - 01 fiUIMO'tS Id.uJoU umlilU ~ '" SL:S s 01' I _"> l' '( -<.;€. '1 _S.')' 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Last Name: I Kr<:isElX".. ,....J~ First Name: I Carl i/}3 "-'~"__._'-._._.~~~,-___..._..J __ Street Name: 1...__.. -----.__J~ City or ZIP: 1....-.1 f}3" Interest: jt-Jo... :..~_e f.:l:":I1_~:.. ___ ........ ..._8 User Name: L_..__.._.__...., ! ....___..J First Name: 1....,._.... ,..... ...._......, State: L~~...I (abbreviations) Last Name: I r""-'" -.--......'...'/ : Search , ... ...; -----..---...--, i Search , Create your orofile Add Listina I He Use of this search form constitute AnvWho terms and conditions. privacy DO , Help Add URL Advertise on Excite Press Releases Jobs(ci)Excite Copyright co 1995.1999 Excite Inc. All rights reserved. Disclaimer EXHIBIT' "111 4/22/99 12:54 PM a new address of p, O. Box 580, New Cumberland. Pennsylvania. 17070. (d) An attempt to serve the Complaint and Plaintiffs Affidavit by mailing them first class regular mail and certified, restricted delivery at P. 0, Box 580, New Cumberland, Pennsylvania, 17070 was made on July 9, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "No Forward Order on File, Unable to Forward, Return to Sender" and "Attempted Not Known". (e) Looking in the local telephone directory. (I) Calling Directory Assistance in the 717 area code. The only listing they had was for a "Carl R. Kreiser" in New Bloomfield, Pennsylvania. This number tUl')1ed out to be the Defendant's parents who stated they have not heard from nor seen their son in years. (g) On July 9, 1998, Plaintiff sent a Request For Change of Address to the Postmaster in New Cumberland, Pennsylvania. The Postmaster returned the request indicating "Not known at address given." (h) On September 23, 1998, Plaintiff sent another Request for Change of Address to the Postmaster in Harrisburg, Pennsylvania. The Postmaster returned the request indicating "No change of address order on file". (i) Another attempt to serve the Complaint and Plaintiffs Affidavit by mailing them first class regular mail and certified, restricted delivery at 1908 North Third Street, Harrisburg, Pennsylvania, 17102, was made on October 7, ] 998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "Forwarding Order Expired" and "Undeliverable as Addressed-Forwarding Order Expired". - 2 - (j) In Novemher 19<)8 and again in February 191)1), Plaintiff contacted a Stuart Wolnak from U. S. Tracing. U. S. Tracing was unable to provide any helpful information in trying to locate the Defendant. (k) A name search in the State of Pennsylvania was conducted through People Finder via the Internet. The search located only one Carl R. Kreiser located in New Bloomfield, Pennsylvania. The listing for Carl R. Kreiser located in New Bloomfield, Pennsylvania is the father of the Defendant. After contacting the Kreiser residence in New Bloomfield, Pennsylvania, Mrs. Kreiser stated that she nor her husband has seen or heard from their son (the Defendant) in years. (I) A name search in the State of Florida was conducted through People Finder via the Internet. The search revealed no one lives in the State of Florida by the name of Carl Kreiser, (m) A letter was sent to the Motor Vehicles Department in Florida requesting information regarding any vehicles registered to the Defendant in the State of Florida. The search revealed no vehicles were registered under the Defendant's name. (n) A letter was sent to an acquaintance of the Defendant regarding the whereabouts of the Defendant. To date, this letter has not been returned nor has a response been received. - 3 - '~' I understand that the statements herein arc made subject 10 18 Pa, Cons. Stat. * 4904 relating to unsworn 1~llsification to authorities and that criminal penalties arc provided thereunder for false statements. ~),. I,) (, ',~., (..'. I' IRA H. WEINSTOCK - 4 - 1 '~ ,oj -',:;.'.',-.>:',{.: .1: .--.----..- ....-..- ,j':_';'J..,~-.:'.__',',?..o '. mJ.T{;':;; ,~,~ ~-. :;'-. t~,,,,., ' ',' . ~{i;k:)~,;,;(,'-',~',.~" ---. I~.."",}... " >-, '\Cl >- :f~,~;i?:~.i,'-:',~" r', _ ',~-: CG. ''''''- I > 1::'; -w.:,/",l,I..,_I", ,"':4.. "".... ? 1/~,'~'l'. ',' ':~ ill ~<C ~"'il\"'~: UJ.": , ),,~ I,:" "t)1,? .,... (),o'e <:tr~:"'~: 'It I; c: I;~ ';"'~":'Io:: ()ro~ ::'~r 'T '.~, - ~(\~ _ .:.J-(n .'ul~~\,L~,: I~'';: ...C'J.. ~_J:::: -I!"l"'~"- .. _.. .. ... (To :z: Il"'\ ;,\' M-""" >- ulw . ',,,It,"l,, ! '....... C ,"..r:s: co a.. $....t;., " ' ,f...."':L: ..... n,;Ji',' J,', :-~ "~~.r~iH .,,11 ~ ~~ en _~ ~ 'r~~~~;-~ ill' '.j ._l:' 0"\ U, ~.vj.J~.I.;': ,~\.,,~, ' . At.i:~ \':J }.'" A' , . ;I~\i. ~" '':\., " ~ ,'( ~ ..~t~t-:r'.', ,1.~", ' "t:<"I0I"'r~k ,.' 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Z'O :,'w:t:J;c:: .,,:'~'8~~ :'::::'/~;'{::;'-'~';:~ ';,~'8 , '~ .,;:~;;Jo ':..ZZ ',iMI to the Postmastcr in Harrisburg, Pennsylvania, The Postmaster returned the request indicating a new uddress of P. O. Box 580, New Cumberland, Pcnnsylvania, 17070. (d) An attempt to serve the Complaint and Plaintiffs Affidavit by mailing them first class regular mail and certified, restric.ted delivery at P. O. Box 580, New Cumberland, Pennsylvania, 17070 was made on July 9, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit wcre returned and markcd "No Forward Order on File, Unable to Forward, Return to Sender" and "Attempted Not Known", (c) Looking in the local telephone directory. (I) Calling Directory Assistance in the 717 area code. The only listing Directory Assistance had was for a "Carl R. Kreiser" in New Bloomfield, Pennsylvania. This number turned out to be the Defendant's parents who stated they have not heard from nor seen their son in years. (g) On July 9,1998, Plaintiff sent a Request For Change of Address to the Postmaster in New Cumberland, Pennsylvania. The Postmaster retumed the request indicating "Not known at address given." (h) On September 23, 1998, Plaintiff sent another Request for Change of Address to the Postmaster in Harrisburg, Pennsylvania. The Postmaster returned the request indicating "No change of address order on file". (i) Another attempt to serve the Complaint and Plaintiffs Affidavit by mailing them first class regular mail and certified, restricted delivery at 1908 North Third Street, Harrisburg, Pennsylvania, 17102, was made on October 7, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "Forwarding - 2 - Order Expired" and "Undeliverable as Addressed-Forwarding Order Expired". (j) In November 1998 and again in February 1999, Plaintiff contacted a Stuart Wolnak from U. S. Tracing. U. S. Tracing was unable to provide any helpful information in trying to locate the Defendant. (k) A name search in the State of Pennsylvania was conducted through People Finder via the Internet. The search located only one Carl R. Kreiser located in New Bloomfield, Pennsylvania, The listing for Carl R. Kreiser located in New Bloomfield, Pennsylvania is the father of the Defendant. After contacting the Kreiser residence in New Bloomfield, Pennsylvania, Mrs. Kreiser stated that she nor her husband has seen or heard from their son (the Defendant) in years. (I) A name search in the State of Florida was conducted through People Finder via the Internet. The search revealed no one lives in the State of Florida by the name of Carl Kreiser. (m) A letter was sent to the Motor Vehicles Department in Florida requesting information regarding any vehicles registered to the Defendant in the State of Florida. The search revealed no vehicles were registered under the Defendant's name. (n) A letter was sent to an acquaintance of the Defendant regarding the whereabouts of the Defendant. To date, this letter has not been returned nor has a response been received. 3. I have been unable to locate any address for the Defendant other than his last known mailing addresses at 1908 North Third Street, Harrisburg, Pennsylvania, ]7]02 or P. 0, Box 5~0, New Cumberland, Pennsylvania, 17070. - 3 - .... FLORA M. KREISER, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. NO. 98-3463 CARL RlCHARD KREISER, Defendant. CIVIL ACTION - IN DIVORCE AFFIDAVIT OF RETURN OF NO SERVICE UPON DEFENDANT CARL RICHARD KREISER Service upon Defendant, Carl Richard Kreiser, of the Complaint in Divorce and Plaintiffs Affidavit was attempted at 1908 North Third Street, Harrisburg, Pennsylvania, 17012 and P. O. Box 580, New Cumberland, Pennsylvania, 17070 on the following dates and in the following manner: (a) A telephone call was made to Reithoffer Shows', Defendant's last known place of employment, home office in Gibsonton, Florida, and they could not verify an employee by the name of Carl R. Kreiser. (b) An attempt to serve the Complaint and Plaintiffs Affidavit by mailing them first class regular mail and certified, restricted delivery at 1908 North Third Street, Harrisburg, Pennsylvania, 17012 was made on June 23, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "No Forward Order on File, Unable to Forward, Return to Sender" and "Undeliverable as Addressed- Forwarding Order Expired". (c) On July 7, 1998, Plaintiff sent a Request For Change of Address to the Postmaster in Harrisburg, Pennsylvania. The Postmaster returned the request indicating a ncw addrcss of P. O. Box 580, New Cumberland, Pennsylvaniu, 17070. (d) An uttempt to serve the Complaint and Plaintiffs Affidavit by mailing thcm lirst class rcgular mail and certified, restricted delivery at P. O. Box 580, New Cumberland, Pennsylvania, 17070 was made on July 9, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "No Forward Order on File, Unable to Forward, Return to Sender" and "Attempted Not Known". (e) Looking in the local telephone directory. (I) Calling Directory Assistance in the 717 area code. The only listing they had was for a "Carl R. Kreiser" in New Bloomfield, Pennsylvania. This number tU'11ed out to be the Defendant's parents who stated they have not heard from nor seen their son in years. (g) On July 9, 1998, Plaintiff sent a Request For Change of Address to the Postmaster in New Cumberland, Pennsylvania. The Postmaster returned the request indicating "Not known at address given." (h) On September 23, 1998, Plaintiff sent another Request for Change of Address to the Postmaster in Harrisburg, Pennsylvania. The Postmaster retumed the request indicating "No change of address order on file". (i) Another attempt to serve the Complaint and Plaintiffs Affidavit by mailing them first class regular mail and certified, restricted delivery at 1908 North Third Street, Harrisburg, Pennsylvania, 17/02, was made on October 7, 1998. Both envelopes containing the Complaint and Plaintiffs Affidavit were returned and marked "Forwarding Order Expired" and "Undeliverable as Addressed-Forwarding Order Expired". - 2 - (j) In November 1998 and again in February 1999, Plaintiff contaetcd a Stuart Wolnak from U. S. Tracing. U. S. Tracing was unablc to provide any helpful information in trying to locate the Defendant. (k) A namc search in the State of Pennsylvania was conducted through People Finder via the Internet. The search located only one Carl R. Kreiser located in New Bloomfield, Pennsylvania. The listing for Carl R. Kreiser located in New Bloomfield, Pennsylvania is the father of the Defendant. After contacting the Kreiser residence in New Bloomfield, Pennsylvania, Mrs. Kreiser stated that she nor her husband has seen or heard from their son (the Defendant) in years. (I) A name search in the State of Florida was conducted through People Finder via the Intemet. The search revealed no one lives in the State of Florida by the name of Carl Kreiser. (m) A letter was sent to the Motor Vehicles Department in Florida requesting information regarding any vehicles registered to the Defendant in the State of Florida. (n) A letter was sent to an acquaintance of the Defendant regarding the whereabouts of the Defendant. To date, this letter has not been returned nor has a response been received. - 3 - "';'1' '" ',~ .,'," '.,:";. 'lfl ~ :')~ .Q=-y .. 'l.l:J' :;>. ~I.:J .' ~t in ~,JZ ~"C 'ffi ,u~.l ' "t)'J. ." , ::;. " (,) ,"', t-t'" ,', ' "', ,'~ ::r:, .' .',!;, "..?" :".p ;.,' \ ;;,,' -";". .,'\" .\'" .',....' !il~ H S~ 1:1 H"J Ci'l0 trJ,~ 2: C"l":l t'ilH ~ H 2: Ci'l ~ ~ "J"J ()2:C"lH 1:11:1 ~;'~2: 00 5l~ H '... 1:1"'~::I: :0 cx)' trJ H :;::;: ~ \' (l C"lW (l, :Ii ... 01'>,2:,0 ~ t:J ~ HO'I,t:Jc:l ~ OW'~ t:J UltrJ 2:"C"l !'3 < ::I:'H 0" ~ tIl t'ilrn I~O ~trJ ' "J trJ . ~ ';...';' H . ~C"l rn ~" 0 t:J t'il I'd JlJ . ,".',~ ro ~ f-' , ,I'd HI . JlJ :;.,' 't'ilO 11> f-'. " ,,2:'2: :l :l JlJ, ,-,-.\ 2: ',",;"r' 0. rt ",::>",.~ JlJ ..,: ..:,: :l HI 'trJ, rt HI '.,~ . Ul ,,' ":"'.('~"'-"-'--"'''''' ',', FLORA M. KREISER, a/k/a FLORA M. DASHER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. No, 98 - 3463 CARL RICHARD KREISER, Defendant. CIVIL ACTION - IN DIVORCE MOTION FOR FINDING OF DUE DILIGENCE Plaintiff, Flora M. Kreiser, aikJa Flora M. Dasher, by and through her attorney, Ira H. Weinstock, Esquire, and pursuant to Pa.R.C.P, No. 1920.4(c), moves this Court to waive service of the Notice of Intention to Request Entry of the Divorce Decree. In support of this Motion, Plaintiff avers as follows: I. After a diligent search the Defendant cannot be located. The diligent search consisted of the following: (a) Plaintiff believes t~at the Defendant has joined a traveling carnival, possibly Reithoffer Shows, and his whereabouts is unknown. A telephone call was made to Reithoffer Shows' home office in Gibsonton, Florida, however they could not verify an employee by the name of Carl R. Kreiser. (b) An attempt to serve the Complaint and Plaintiffs Affidavit was made by mailing them first class regular mail and certified, restricted delivery to his last known address at 1908 North Third Street, Harrisburg, Pennsylvania, 17102 on June 23, 1998. Both envelopes containing the Complaint and Plaintirrs Affidavit were returned and marked "No Forward Order on File, Unable to Forward, Return to Sender" and "Undeliverable as Addressed-Forwarding Order Expired". (c) On July 7,1')')8. PlaintilTsent a Iteqnl'st For Change of Addrcss to thc Postmaster in Harrisburg. Pennsylvania. The Poslmaster relnrned Ihe request indicating a new address of P. O. Box 580, New Cumherland. Pennsylvania. 171)71), (d) An attcmpt tll servc the Complaiul aud Plainlifl's Anidavil was made by mailing them first class regular mail and certilicd, restricted delivery at 1'. 0, Box 580, New Cumberland, Pennsylvania, 17070 on July 9, 1')1)8, Iloth envelopcs containing the Complaint and PlaintiWs Affidavit were returned and markcd "No Forward Order on File, Unable to Forward, Return to Sender" and "Attempted Nol Known". (e) No listing for thc Defendant appcared in the loeallelephone directory. (I) A call was made to Directory Assistance in the 717 area code and the operator indicated there was a listing lor a "Carl R, Kreiser" in New Bloomfield, Pennsylvania. This number turned oulto he the Defendant's parents who stated they have not heard from nor seen thei r son in years. (g) On July I), 1998, Plainti IT scnt a Request For Change of Address to the Postmaster in New Cumberland, Pcnnsylvania, The Postmaster returned the request indicating "Not known at address given." (h) On Septemher 23, 1998, Plaintiff sent another Request for Change of Address to the Postmaster in Harrishurg. Pennsylvania, The Postmaster returned the request indicating "No change of address ordcr on Ii Ie". (i) Another attempt 10 serve the Complaint and Plaintiff's Affidavit was made by mailing them first class regular mail and certified, restricted delivery at 1908 North Third Street, Harrisburg, Pennsylvania, 17102, on October 7, 1998. Both envelopes containing the Complaint and Plaintirrs Affidavit were returned and marked "Forwarding Order Expired" and "Undeliverable as Addressed-Forwarding Order Expired". OJ In November 1998 and again in February 1999, Plaintiff contacted a Stuart Wolnak from U. S. Tracing. U. S. Tracing was unable to provide any helpful information in trying to locate the Defcndant. (k) A name search in the slate of Pennsylvania was conducted through People Finder via the Internet. The search located only one Carl R. Kreiser located in New Bloomfield, Pennsylvania. The listing for Carl R. Kreiser located in New Bloomfield, Pennsylvania is the father of the Defendant. After contacting the Kreiser residence in New Bloomfield, Pennsylvania, Mrs. Kreiser stated that she nor her husband has seen or heard from their son (the Defendant) in years, (1) A name search in the state of Florida was conducted through People Finder via the Intemet. The search states "No entries match your query." (m) On March 2, 1999, a letter was sent to the Department of Highway Safety and Motor Vehicles in Tallahassee, Florida requesting car registration information concerning the Defendant. The Department of Highway Safety and Motor Vehicles returned the letter with a notation stating "Not Registered". (n) On March 2, 1999, a letter was sent to an acquaintance of the Defendant asking for any information she would be willing to share regarding the whereabouts of the Defendant. To date, the letter was not returned nor was a response