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Home My WebLink About12-3880UN' KML LAW GROUP, P.C. Suite 5000 BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 825-6319 for Plaintiff 2 J; ETA 10 n w 4 R" ADD C0UN? T' CITIMORTGAGE INC. 1000 Technology Drive O'Fallon, MO 63304 Plaintiff vs. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY DAVID CORBITT SR. JEANNIE L. CORBITT CIVIL ACTION - LAW and OCCUPANTS 153 East Columbia Road ACTION OF EJECTMENT Enola, PA 17025 Defendants Tenn ?$$a lV t No. 1 a. 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 the 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 claim in the Complaint of 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 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 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 A 7 iuao( AVISO VN?(0 4? g1 LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE LISTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT Plaintiff is CITIMORTGAGE INC., with an address of 1000 Technology Drive, O'Fallon, MO 63304. 2. Defendants are DAVID CORBITT SR., JEANNIE L. CORBITT, and OCCUPANTS. 3. The Defendants, DAVID CORBITT SR., JEANNIE L. CORBITT and OCCUPANTS, occupy the property located at 153 East Columbia Road, Enola, PA 17025 ("the Property") and do so without right, and so far as the Plaintiff is informed, without claim of title. 4. Plaintiff is the owner of the Property by virtue of a Deed from the Sheriff of Cumberland County to Plaintiff that was recorded on 4/25/2012 at Instrument # 201211997 in the Recorder's Office of Cumberland County. A true and correct copy of the Sheriff s Deed containing the description of the Property is attached to this Complaint. 5. Plaintiff is entitled to immediate possession of the Property. 6. Plaintiff has demanded possession of the Property from the Defendants who have refused to deliver up possession. WHEREFORE, Plaintiff requests judgment for possession of the Property. By: LA GROUP, P.C. Jay E. Kivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff VERIFICATION E 5 tree /? ob inso n hereby states that he/she is the A55J i (-e- ?'1151J(Af-of Plaintiff in this matter, CITIMORTGAGE INC., and that all of the facts set forth in the attached Plaintiffs Complaint are true and correct to the best of his/her information and belief. The undersigned understands that statements herein are made subject to the penalties of 18 P.S. §4904. CITIMORTGAGE By: Printed Name: b r Robinson Title: ASSM. ,,-t, President t)t tnc. /REO DeP, M estet.ro msom-citf.-l- FILE#: 114464EJ REO ID#: PROPERTY: 153 East Columbia Road Enola PA 17025 Corbi4+ EXHIBIT "A" SHERIFF' S DEED FILE#: 114464EJ PROPERTY: 153 East Columbia Road Enola PA 17025 Know all Men by these Presents That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sutn of S 1.00 (One Dollar), to me in hand paid, do hereby grant and convey to Citimortgage, Inc. 2009-6224 Civil Term Citimortgage Inc. VS David Corbitt Sr. and Jeannie L. Corbitt All that certain tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described according to a survey by Gerrit J, Betz, R.S., dated August 17, 1976, as follows, to wit: Beginning at a point on the Northern line of Columbia Road, said point being by same measured in a northeasterly direction a distance of 75 feet from the northeast corner of North Enola Drive (formerly Altonna Avenue) and Columbia Road; thence North 14° 56' { 30" West along the eastern line of lands N/F of Martin and being along and through the centerline of a partition wall and beyond a distance of 286.50 feet to a point on the Southern line of Shady Lane; thence North 75° 07' East along the Southern line of Shady Lane a distance of 25.20 feet to a point; thence South 14° 56' 30" East along the Western line of lands N/F of Bixler a distance of 286.472 feet to a hub in the Northern line of Columbia Road, aforesaid; thence South 72° 03'30" West along said Northern Line a distance of 25.20 feet to the point and Place of Beginning. Parcel No, 09-13-1002-257 BEING KNOWN AS: 153 East Columbia Road, Enola, PA 17025 BEING the same premises which Jeannie L. Corbitt, formerly known as Jeannie L. Edinger by deed dated 7/14107 and recorded 7/24/07 in Cumberland County In Deed Book Volume 281 at Page 404 granted and conveyed unto Jeannie L. Corbitt and David Corbitt Sr., wife and husband The same having been sold by me to the said grantee on the 7th day of March, Anno Domini Two Thousand and Twelve (2012) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 12th of October Anno Domini 2011 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nine (2009) Number 6224 at the suit of Citimortgage Inc. vs David Corbitt Sr. and Jeannie L. Corbitt. In Witness Whereof, I have hereunto affixed my signature this Anno Domini Two Thousand and Twelve (2012) Commonwealth of Pennsylvania, ss. County of Cumberland 5th dayof .April Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 5 th day of April Anno Domini Two Thousand and Twelve (2012) l?pF?pYwt"flnt 01i1Ma??tlN ? SRI fir, ???rJl7 s ;. 'S? - ? ti.1% :. I hereby certify that the residence And Post Office address of the Within Grantee is 1000 Technology Drive O'Fallen, MO 63304 Solicitor (v ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201211997 Recorded On 4/25/2012 At 9:09:30 AM * Instrument Type - DEED-SHERIFF'S Invoice Number -106789 User ID - KW * Grantor - CORBITT, JEANNIE L * Grantee - CITIMORTGAGE INC * Customer - SHERIFF * FEES STATE SPRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 EAST PENNSSORO SCHOOL $0.00 DISTRICT EAST PENKSBORO TOWNSHIP $0.00 TOTAL PAID $63.00 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O D DS " - Information denoted by an asterisk may change daring the verification process and may not be reflected on this page. 00AiCX 11 MINIM 111 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R F Tj? t" F1 y ? fit. roJ Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor gt?ttt?, at tttrtT,>rl?jtb CITIMORTGAGE, Inc. vs. David Corbitt, Sr. (et al.) Case Numbe 2012-3880 2512 ?I 12 P C CUPENNSYLVN i? IA i SHERIFF'S RETURN OF SERVICE 07/06/2012 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: Occupant of 153 E. Columbia Road, Enola, Pennsylvania 17025, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Occupant. Request for service at 153 E. Columbia Road, Enola, Pennsylvania 17025 is vacant. 07/06/2012 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: Jeannie L. Corbitt, but was unable to locate her in h s bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Jea nie L. Corbitt. Request for service at 153 E. Columbia Road, Enola, Pennsylvania 17025 is vacant. 07/06/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent se rch and inquiry for the within named defendant to wit: David Corbitt, Sr., but was unable to locate him in h bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Dav d Corbitt, Sr. Request for service at 153 E. Columbia Road, Enola, Pennsylvania 17025 is vacant. SHERIFF COST: $90.00 SO ANSWERS, July 09, 2012 R ANDERSON, SHERIFF G , y, " , Sher fi. 1' - o, so; . Li: ?? I?.E.t?-O>= FICE ME PROTHONOTARY KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff MP AUG-6 Ae 10: 54 1,-JUMSERLAND COUNTY PENNSYLVANIA CITIMORTGAGE INC. 1000 Technology Drive O'Fallon, MO 63304 vs. DAVID CORBITT SR. and JEANNIE L. CORBITT and OCCUPANTS 153 East Columbia Road Enola, PA 17025 OF Cumberland COUNTY No. 12-3880-Civil THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: Plaintiff is the legal owner of the premises 153 East Columbia Road, Enola, PA, 17025 pursuant to a deed from the Sheriff of Cumberland County. 2. Plaintiff filed a Complaint in Ejectment on June 20, 2012. 3. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, Jay E. Kivitz, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. 4. Sheriff has been unable to effect service of the Complaint because the property appears to be vacant. Following Plaintiff s good faith effort to locate Defendants, Plaintiff has still been unable IN THE COURT OF COMMON PLEAS to effect service upon Defendants. 6. As this is an action for possession, further investigation is unnecessary. 7. Defendants have no right, title or interest in the premises, 153 East Columbia Road, Enola, PA, 17025. Plaintiffs inability to affect personal service upon Defendants has deprived, and continues to deprive Plaintiff of the use and possession of which it is the lawful owner. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint/Writ upon Defendants by posting the premises and certified and regular mail to the Defendants' last known address. By. rl Xtxr- LA GROUP, P. t. /Jay . Kivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 10,1111p at 4?thb?ryA4# Q.-ICE or THE st-cpIGF CITIMORTGAGE, Inc. vs. Case Number David Corbitt, Sr. (et al.) 2012-3880 SHERIFF'S RETURN OF SERVICE 07/06/2012 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Occupant of 153 E. Columbia Road, Enola, Pennsylvania 17025, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Occupant. Request for service at 153 E. Columbia Road, Enola, Pennsylvania 17025 is vacant. 07/06/2012 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jeannie L. Corbitt, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Jeannie L, Corbitt. Request for service at 153 E. Columbia Road, Enola, Pennsylvania 17025 is vacant. 07/06/2012 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: David Corbitt, Sr., but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant David Corbitt, Sr. Request for service at 153 E. Columbia Road, Enola, Pennsylvania 17025 is vacant. SHERIFF COST: $90.00 July 09, 2012 SO ANSWERS, 4RON51-- M Gamr,9.1ite Shmm Toac... Inc. Affidavit of Good Faith imreslbgafiorf At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identifie as the subject below. The following is true and accurate representation of my investigation. PMVI died information: File Number: 114464EJ Attomey/Law Firm: KML LAW GROUP, P.C Subject Name: DAVID CORBITT SR. Property Address: Street: 153 East Columbia Roam City: Enola State: PA Zip: 17025 Skip : Date of Birth: 02/1311959 ProVest File Number. 3353836 Last Known Address (as of 7/26/2012) Street 153 E COLUMBIA RD City: Enota State: PA Zip: 17025 2404 Death Reoord Search As of 07/2612012, the Social Security Administration has no death record on f e for David Corbitt Sr Sonia! Security Number [XI Verifed [ ] Not Verified SSN# XXX-XX-XX56 Emoornek search During a search for employment of our defendant no employment information was provided prior to the investigation or found during the Investigation,. w*HM Record8 giia No verifiable business records found, Cftdftr Header lnctiliry The latest address from the credit header info is: Address: 153 E COLUMBIA RD, ENOLA, PA 17025 2404 D"artment of Motor ehk ReCa? Search* Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Otfvers L wuo h*r>1 rrt Search License: I ] G+ovemmenilla!"+ Name: DAVID A CORBITT [Xj Norrj?ltlritad DL #: 22661503 State Name: Pennsylvania dress: 153 E COLUMBIA RD, ENOLA, PA 17025 2404 Non Governmental: Y Issue Date: No issue date reported. Expiration Date: No expiration data reported, Pr'dfi9oebtfal Ucerts" Suit No current records €ound. Froadom Of lr*mwfion Act km he following addresses were sent to the United. States Postal inspector at the Made to U.S. Postal Service zip code listed with no return information to date: 153 EAST COLUMBIA ROAD [ ENOLA I PA 17425 ) CUMBERLAND COUNTY MMbWy Search of on Active Duty; Did not leave Active Duty within the past 367 days; Hann been notified of a future call up to Active Duty 717.695-3984: Called possible neighbor, Brett Haulman, number has been 8 ? disconnected. 717-695-2463: Calved number listed to co-defendant, Jeannie Corbitt, number has been disconnected, 717-635-9997: Called number listed to defendant, David orbitt, generic answering machine answered, no message left. WOKO MROvgli UM'n" smc, %^, ra, W, OR, PA, VA, VvA. - Wsroncat Oara to CQ, Dt, !D, tL, KY, LA, MD, MA, MS, MO. NH, NO, SC, WV, + Data avaAabte in CO, CT, DE, FL, 10, fL, KY, LA ME, MD, M.A. Ml, MN. MS,MO, NH. ND. OH. SC, TN, TX, WV, wl, WY. The We -V statement is true and correct. i understand that false statements herein are msde subject to the penalties Of 18 Pa.C.S.A. §4904 rselati to unswixn tal3iftt0tkm to authorities: Linder penalties of perjury, I declare fhat 1 have read ft foreong aflidavit and that the facts stated in it are tru . / STATE OF FLORIDA l w - COUNTY OF HILLSBOROUGH JUL 2 6 2012 na Hernandez Sworn to or aftarned and signed before ne on this ___. day of Provest Services LLC (Seat) 7126t2012 KATtI" RAGKETT NOTARY PtlBUG; STATE OF FLORpA . Ccmm? EE0?3 Expltsa 511112t?15 (C,r4sonegy Known ( )Produced ed Name of Notary Putific as identification Affidavit of Good Falth investigation At the request of the taw firm identified below I initiated an investigation into the whereabouts of the defendant identi red as the subject below. The following is true and accurate representation of my investigation. Cleat pro vlded k0ormation: File Number, 114464EJ Attorney/Law Firm: KML LAW GROUP, P.C Subject Name: JE4NNJE L. CORBfTT Property Address: Street: 153 East Columbia Road City: Enola State: PA Zip; 17025 Sid p Rem: Date of Birth 07%2711960 ProVest Fite Number: 3353836 Last Known Address (as of 712612012) Street: 153 E COLUMBIA RD City: Enola State: PA Zip: 17025 2404 Death Record Search As of 07/2612012, the Social Security Administration has no death record o file for Jeannie L Corbitt. Social Security NuirrArer l [X) Verifed [ I Not Verified SSN* XXX-XX-XX69' Envloyment Search During a search for ernployment of our defendant no employment informat' in was provided prior to the investigation or found during the Investigation. Busirmns Records Search No verifiable business records found. Creditor Header Inquiry The latest address from the credit header info is: Address: 153 E COLUMBIA RD, ENOLA, PA 17025 2404 Depwboent of Motor Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Vehicle Records Search* D dym License lrdDrnwdion Search No current records found. } 1 Prt for d Licensee Search No current records found. Fresddrn Of Act IrKlulry The following addresses were sent to the United States Postal inspector at he Made to U.S. Postal Service zip code listed with no return information to date: PO BOX 401 MECHANICSBURG PA 117055 00401 CUMBERLAND 153 EAST COLUMBIA ROAD 1 ENOLA I PA 1 170251 CUMBERLAND COUNTY Search Not on Active Duty, Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty N b S Frt 717-695-3984: Called possible neighbor, Brett Haulrrtan, number has been di t d eoi om sconnec e . Comm wits: 717-635-9997: Called number listed to defendant, Jeannie Corbitt, generic answering machine answered, no message left. 717-695-2463: Called number listed to defendant, Jeannie Corbltt, number as been disconnected. - irate riot avanacte tn,t?u AR; CA. M, Nh. UK. PA. V& WA- -- ftistorrcat data in CO, DE, V. 11, KY, LA, MD, MA, MS, MO. NH, ND, SC. WV. + Data available in CO, CT, DE, FL, ID, II.KY, LA, ME, MD, MA, MI, MN, MS', MO, NH, ND, OH, SC, TN; TX, WV, WI, WY. The foreparrt? statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A 904 re to unswom falsltir?on to authontles. Under penatiies of perjury, l declare that i have read the foregoing affidavit and that the facts star in It are STATE OF FLORIDA 4" t r COUNTY of HILLSBOROUGH JUL 2 6 2012 Gianna Hernandez Swom to or affirmed and signed before me on this day of Provest Services LLC (Seal) 7!2812012 KATH" RACKETT NOTARY PUBLIC STATE OF fLG1ttIDA r? "? y re of rY Public SJt 1!1!01 tl Printed Name of Notarp Iblia -- KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CITIMORTGAGE INC. 1000 Technology Drive O'Fallon, MO 63304 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. DAVID CORBITT SR. and JEANNIE L. CORBITT and OCCUPANTS 153 East Columbia Road Enola, PA 17025 VERIFICATION No. 12-3880-Civil Attorney for Petitioner does hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. By: K*L W GROUP, C. a E. Kivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CITIMORTGAGE INC. 1000 Technology Drive O'Fallon, MO 63304" vs. DAVID CORBITT SR. and JEANNIE L. CORBITT and OCCUPANTS 153 East Columbia Road Enola, PA 17025 OF Cumberland COUNTY Term No. 12-3880-Civil MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P 430(a) Plaintiff has filed a Complaint in Ejectment, against Defendants which the Sheriff has been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendants whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Ejectment upon Defendants by posting the premises and certified mail and regular mail to the Defendants' last known address. By: LA GROUP, P. O. Jay . Kivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CITIMORTGAGE INC. 1000 Technology Drive O'Fallon, MO 63304 IN THE COURT OF COMMON PLEAS of Cumberland County vs. DAVID CORBITT SR. JEANNIE L. CORBITT and OCCUPANTS 153 East Columbia Road Enola, PA 17025 No. 12-3880-Civil CERTIFICATE OF SERVICE Matthew Amato, does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendants this 'rd day of v? v S4, 2012, by first class mail, postage prepaid. DAVID CORBITT SR. 153 East Columbia Road Enola, PA 17025 JEANNIE L. CORBITT 153 East Columbia Road Enola, PA 17025 OCCUPANTS 153 East Columbia Road Enola, PA 17025 By: AW GRO , P.C. w A mato latthe , L gal Assistant t Main Phone: 215-627-1322 CITIMORTGAGE INC. vs. DAVID CORBITT SR. and JEANNIE L. CORBITT and OCCUPANTS 153 East Columbia Road Enola, PA 17025 ORDER AND NOW, this 001h day of IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 12-3880-Civil A U I u A T 2012, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants, have been unsuccessful, it is, ORDERED and DECREED: That Plaintiffs Motion is granted. The Sheriff and/or Plaintiff is directed to Serve the Complaint in Ejectment upon Defendants by posting a copy of the Complaint upon the premises 153 East Columbia Road, Enola, PA, 17025, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 153 East Columbia Road, Enola, PA, 17025. All further service of legal papers, including but not limited to Motions, Petitions and Rules, may be made by certified and regular mail to Defendants' last known address(es); and service of the Writ of Possession may be made upon Defendants by sending copies of same to Defendants' last known address(es) by certified and regular mail and by posting the premises, 153 East Columbia Road Enola, PA 17025. BY THE COURT: J. r Distribution list: rnrn 09 09 '" f 7.S. P.C., Suite 5000 - BNY Independence Center, 701 Market KML Law Group treet, a M c r , Philadelphia, PA 19106-1532 r ° r'' DAVID CORBITT SR., 153 East Columbia Road Enola, PA 17025 ' ;T JEANNIE L. CORBITT, 153 East Columbia Road Enola, PA 17025 : e t ?? r•? F . c , o Z ? ?[.?;#'?' bawd plel,*Oe `Pll