Loading...
HomeMy WebLinkAbout10-6942 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 „ _`) r~ ATTORNEY FOR PLAINTIFF 248133 COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff V. GEOFF TIMOTHY JENNIFER MAY 504 HOGESTOWN ROAD MECHANICSBURG, PA 17050-2610 TERM Nil I" NO. to - (p9467 a, CUMBERLAND COUNTY Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE \`S 4ga.00 PA ATE e`? 1?193[0l 2* a5o54y File #: 248133 NOTICE You have been sued in Court. If you wish to defend against the claims 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 DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 248133 1. Plaintiff is WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: GEOFF TIMOTHY JENNIFER MAY 504 HOGESTOWN ROAD MECHANICSBURG, PA 17050-2610 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 01/29/2008 GEOFF TIMOTHY and JENNIFER MAY made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR FRANKLIN AMERICAN MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200803400. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 248133 6 The following amounts are due on the mortgage: Principal Balance $135,632.98 Interest $4,668.03 03/01/2010 through 10/22/2010 (Per Diem $19.7798) Attorney's Fees $650.00 Late Charges through 10/22/2010 $155.48 Property Inspections/Property Preservations $15.00 Non Sufficient Funds Charge $20.00 Mortgage Insurance Premium / $107.62 Private Mortgage Insurance Costs of Suit and Title Search $550.00 Escrow Deficit $913.45 TOTAL $142,712.56 7 8 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 248133 9. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $142,712.56, together with interest from 10/22/2010 at the rate of $19.7798 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the HALLINAN & SCHMIEG, LLP By: U Lawrence T. Phelan, Esq. Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judi Romano, Esq., Id. No. 58745 F0 Sh tal R. Shah-Jani, Esq., Id. No. 81760 ? nine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 248133 LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point in the Hogestown Road (L.R. #416), said point being located at a distance of one hundred twenty (120) feet, more or less, North of the centerline of Texaco Road; thence in and along the Hogestown Road, North 02 degrees 39 minutes West, a distance of eighty-three and thirteen hundredths (83.13) feet to a point in the pavement of said Road; thence among lands now or formerly of Dean E. Lebo. North 83 degrees 52 minutes East, a distance of one hundred seventy-seven (177.00) feet to an iron pin; thence along lands now or formerly of Richard C. Roth, South 01 degree 39 minutes East, a distance of ninety-six and fourteen hundredths South 88 degrees 05 minutes West, a distance of one hundred seventy-five (175.00) feet to the point of Beginning. Containing 15,755 square feet of land. Being Tax Parcel No. 38-20-1831-075. Also being known as 504 Hogestown Road. File 4: 248133 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to DATE File #: 248133 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE or THE Pi30 H NJT,,AiRy Sheriff - Jody S Smith ti s 21?!U DEC -8 PM 3:49 Chief Deputy Richard W Stewart CUMBERLAND COMTY 'EN,N5YL N11 A Solicitor Wells Fargo Bank, NA Case Number vs. Timothy Geoff (et al) 2010-6942 SHERIFF'S RETURN OF SERVICE 11/04/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Jennifer May, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 11/18/2010 02:29 PM - Dauphin County Return: And now November 18, 2010 at 1429 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jennifer May by making known unto Jennifer May now known as Jennifer Timothy, personally at 248D Society Park Court, Harrisburg, Pennsylvania 17110 its contents and at the same time handing to her personally the said true and correct copy of the same. 11/30/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jennifer May, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Jennifer May. Request for service at 504 Hogestown Road, Mechanicsburg, Pennsylvania 17050 is vacant. 12/06/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Timothy Geoff, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Timothy Geoff. Request for service at 504 Hogestown Road, Mechanicsburg, Pennsylvania 17050 is vacant. To date The Mechanicsburg Postmaster was unable to provide a good forwarding address for Timothy Geoff. SHERIFF COST: $88.00 December 06. 2010 SO ANSWERS, RON W R ANDERSON, SHERIFF (ptfirit o the Si4criff William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin WELLS FARGO BANK NA VS JENNIFER MAY Sheriff s Return No. 2010-T-3393 OTHER COUNTY NO. 20106942 And now: NOVEMBER 18, 2010 at 2:29:00 PM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon JENNIFER MAY by personally handing to JENNIFER MAY 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 248 D SOCIETY PARK CT HARRISBURG PA 17110 JENNIFER MAY IS NOW KNOWN AS JENNIFER TIMOTHY Sworn and subscribed to before me this 24TH day of November, 2010 -)P? Z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 So Answers, ?°lc- Sheriff. of Davin C By?dr*v fem. Deputy Sheriff Deputy: W CONWAY Sheriffs Costs: $47.25 11/8/2010 s" Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. FILED-OFFICE OF THE PROTHONOTARY 2010 DEC 30 AM 10: 41 CUMBERLAND COUNTY PENNSYLn?ANIA ATTORNEY FOR PLAINTIFF COURT' OF COMMON PLEAS Plaintiff vs. GEOFF TIMOTHY JENNIFER MAY Defendants : CIVIL DIVISION CUMBERLAND COUNTY : No. 10-6942 CIVILTERM PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE ?? ?oy?S?ao ?-? asap K TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. SCHMIEG, LLP B LJ awrence T. Phelan, I q., Id. No. 32227 ? F ancis S. Hallinan, sq., Id. No. 62695 ? iel G. Schmieg, Esq., Id. No. 62205 ? ichele M. Bradford, Esq., Id. No. 69849 ? J dith T. Romano, Lsq., Id. No. 58745 heetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, lsq., Id. No. 206779 ? Andrew C. Bramblctt, 1?sq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 Attorneys for Plaintiff Date: December 29, 2010 /tam, Svc Dept. File# 248133 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FH rJ 017F1`-- Sheriff r ttiip ul un+be?lr i'i wl??01T? Jody S Smith r r Chief Deputy 12 L r nr ,r Richard W Stewart 7 t 1". ? A R '? e^f 4 4 SO/ICItOr i.,?a, Wells Fargo Bank, NA vs. Case Number Timothy Geoff (et al.) 2010-6942 SHERIFF'S RETURN OF SERVICE 01/03/2011 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Timothy Geoff, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 01/06/2011 07:28 PM - Dauphin County Return: And now January 6, 2010 at 1928 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Timothy Geoff by making known unto himself personally, at 4248D Society Court, Harrisburg, Pennsylvania 17110 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 10, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (Ptfire Of #hE' *hcrr-ff William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin WELLS FARGO BANK, NA VS GEOFF TIMOTHY Sheriff s Return No. 2011-T-0039 OTHER COUNTY NO. 20106942 And now: JANUARY 6, 2011 at 7:28:00 PM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon GEOFF TIMOTHY by personally handing to GEOFF TIMOTHY 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 4248D SOCIETY COURT HARRISBURG PA 17110 Sworn and subscribed to before me this 7TH day of January, 2011 -)P*92) COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires Au ust 17, 2014 So Answers, ,? ezl*= Sheriff of Dauukin ( By- Z,g %/r : 0" i Deputy: W CONWAY Sheriffs Costs: $47.25 1/5/2011 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff vs i 11 sEF I S AN 12X >4?ney For Plaintiff 11'1,MBERLAND COUNTIL' pENNSYLVANiA : Court of Common Pleas : I Civil Division GEOFF TIMOTHY CUMBERLAND County JENNIFER MAY No. 10-6942 CIVILTERM Defendant SUGGESTION OF RECORD CHANGE RE: DEFENDANT'S NAME ON DOCKET TO THE PROTHONOTARY: Defendant's name was erroneously listed on the docket as: GEOFF TIMOTHY JENNIFER MAY The correct name for the Defendant is: GEOFF TIMOTHY JENNIFER MAY A/K/A JENNIFER TIMOTHY Kindly change the information on the docket. Date: 11 1? -fi PI" HALLINAN &AHMIEG, LLP ? Lawr ce . helan, Esq., Id. No. 3 227 ? Fran ' S. Hallinan, Esq., Id. No. 695 ? Dan G. Schmieg, Esq., Id. No. 2205 ? Mic le M. Bradford, Es q., Id. No. 69849 ? Jud T. Romano, Esq., Id. No. 58745 eetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter]. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 PHS # 248133 ? Melissa J. Scheiner, Esq., Id. No. 308912 Attorneys for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff vs GEOFF TIMOTHY JENNIFER MAY Defendant 2011 SEF 15 AM 10*- 1),9 Attorney For Plaintiff CUMBERLAND COUNTY PENNSYLVANIA Court of Common Pleas Civil Division CUMBERLAND County No. 10-6942 CIVILTERM CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: GEOFF TIMOTHY 3 824 DURHAM ROAD HARRISBURG, PA 17110-1525 Date: q1A i PHS # 248133 JENNIFER MAY 504 HOGESTOWN ROAD MECHANICSBURG, PA 17050-2610 By: ? riS. lan, Esq., d. No. 32227 ? an, Esq. d. No. 62695 eg, Es q., Id. No. 62205 ? ford, Es q., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ?heetal R. Shah-Jani, Esq., Id. No. 81760 enne R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Schemer, Esq., Id. No. 308912 Attorneys for Plaintiff FILED-OFFICE OF THE PROTHONOTARY Phelan Hallinan,LLP 7B13 ApR 23 "AM 14' 1 6 ttorney For Plaintiff 1617 JFK Boulevard,Suite 14ggJMBERLAND.COUNT One Penn Center Plaza PENNSYLVANIA Philadelphia,PA 19103 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division vs CUMBERLAND County GEOFF TIMOTHY JENNIFER MAY No. 10-6942 CIVILTERM Defendant PRAECIPE TO THE PROTHONOTARY: ❑ Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ® Please mark the above referenced case Settled, Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice: ❑ Please mark the in rein judgment Satisfied and the action Discontinued and Ended. ❑ Please Vacate the Judgment entered. Date: 2 PH aLANH AN,LL By Joseph A.D s ye,Es d.No.200479 Atto ey for Plaintiff PHS#248133 a ,-, z c13 c� ' 2 =N© =5;c V N c—n ..D i Phelan Hallinan,LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Perin Center Plaza Philadelphia,PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County GEOFF TIMOTHY No. 10-6942 CIVILTERM JENNIFER MAY Defendant PHS#2481.33 CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: GEOFF TIMOTHY JENNIFER MAY 4248 SOCIETY PARK CT APT D HARRISBURG,PA 17109-4943 Date: ( 7 PHE AN HAL AN, LLP By: Joseph A. e oye,Es . . No.200479 Attorney for laintiff