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PHELAN HALLINAN, LLP
John Michael Kolesnik, Esq., Id. No.308877
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.
3476 STATEVIEW BOULEVARD
FORT MILL, SC 29715
Plaintiff,
vs.
CIVIL DIVISION
JOSEPH HUNTER JACOBS
2 BRENTWOOD ROAD
CAMP HILL, PA 17011-2503
Defendant.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes WELLS FARGO BANK, N.A., by its attorneys, Phelan Hallinan, LLP
and files this Complaint in Mortgage Foreclosure as follows:
The Plaintiff is WELLS FARGO BANK, N.A., 3476 STATEVIEW
BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff']
2. The Defendant, JOSEPH HUNTER JACOBS, is an individual whose last known
address is 2 BRENTWOOD ROAD, CAMP HILL, PA 17011-2503.
w~k~1d , ~S,~a
062-PA-V3 ~ ~~
3. WELLS FARGO BANK, N.A., directly or through an agent, has possession of the
Promissory Note. WELLS FARGO BANK, N.A. is either the original payee of the Promissory
Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory
Note is marked Exhibit "A", attached hereto and made a part hereof.
4. On or about April 29, 2009, JOSEPH HUNTER JACOBS made, executed and
delivered to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC AS NOMINEE
FOR M&T BANK a Mortgage in the original principal amount of $206,240.00 on the premises
described in the legal description marked Exhibit "B", attached hereto and made a part hereof.
Said Mortgage being recorded in the Office of the Recorder of CUMBERLAND County in
Instrument No. 200914613. The Mortgage is a matter of public record and is incorporated herein
by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its
obligation to attach documents to pleadings if those documents are of public record.
5. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded March
26, 2012, the mortgage was assigned to WELLS FARGO BANK, NA. which Assignment is
recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 201208568.
The Assignment is a matter of public record and is incorporated herein by reference in
accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach
documents to pleadings if those documents are of public record.
6. JOSEPH HUNTER JACOBS is record and real owner of the aforesaid mortgaged
premises.
7. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the monthly installments of principal and interest due July 1, 2012.
062-PA-V3
8. As of 01/23/2013, the amount due and owing Plaintiff on the mortgage is as
follows:
Principal Balance $203,105.59
Interest $ 4,901.98
06/01 /2012 through O 1 /23/2013
Late Chazges $ 145.23
Property Inspections $ 60.00
Escrow Deficit $ 23.44
Suspense Balance $ (1,108.98)
TOTAL $207,127.26
plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania
Law, actually and reasonably incurred by Plaintiff; including but not limited to, costs (including
escrow advances) and Plaintiff s attorneys' fees and expenses. Plaintiff reserves the right to file
a motion in the above-captioned action to add such additional sums authorized under the
Mortgage and Pennsylvania Law to the above amount due and owing when incurred.
9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of
Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended
in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have
been sent to the Defendant(s).
10. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff
is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to
do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of
personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish
such liability.
062-PA-V3
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the
amount due of $207,127.26, with interest thereon plus additional costs (including additional
escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the
mortgaged premises.
Date: ~f~~
By: _
J
Michael Kolesnik, Esq., Id. No.308877
nev for Plaintiff
062-PA-V3
Exhibit "A"
` ~ ._
NOTE
NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUT THE
OR ITS AUTHORIZED AGENTTMENT OF VETERANS AFFAIRSC
April 29, 2009 Camp Hill PENNSYLVANIA
[Date) 1CitYl [State)
2 Brentwood Road
Carp Hill, PA 17011
(Property Addrtss{
1. BORROWER'S PROMISE TO PAY
In return for a loan that I have received, 1 promise to pay U.S. $ 206, 240.00 (this amount is called "Principal"),
plus interest, to the order of the Lender. The Lender is M6T sank
I will make al! payments under this Note in the form of cash, check or money order.
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is
entitled to receive payments under this Note is called the "Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly
rate of 5.500 %.
The interest rate required by this Section 2 is the rate 1 will pay both before and after any default described in Section 6{B)
of this Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by making a payment every tnonth.
I will make my monthly payment on the 1st day of each month beginning on Junes 01, 2009 . [will
make these payments every month until I have paid all of the principal and interest and any other charges .described below that 1
may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest
before Principal. If, on May 01, 2039 , 1 still owe amounts under this Note, I will pay those amounts in full on
that date, which is called the "Maturity Date."
i will make my monthly payments at PO sox 62182 , Baltimore, 1•ID 21264
or at a different place i[ required by the Note Holder.
(B) Amount of Monthly Payments
My monthly payment will be in the amount of U.S. $ 1,171.01
4. BORROVI°ER' S RIGHT TO PREPAY
The Borrower shall have the right to prepay at any time, without premium or fee, the entire indebtedness or any part
thereof not less than the amount of one installment, or $100.00, whichever is less. Any Prepayment in full of the indebtedness
shall be credited on the date received, and no interest may be charged thereafter. Any partial Prepaymm~t made on other than an
installment due date need not be credited until the neat following installment due date or 30 days after such Prepayment,
whidtever is earlier.
PENNSYLVANIA FIXED RATE NOTE-Singla Family-Fannis MaelFreddis Mac UNIFORM INSTRUMENT
Amended to Veta'ana Aftaks
Form 32110 1101
Amended 8/00
Wolters Kluwer Financial Services
VMP®-SG[PA) to7o~l
Pape 1 of 3 Initiak:
5. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loam charges, is finally interpreted so that the interest or other
loan charges rnllected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge
shall'be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from
me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the
Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated
as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Lale Charge for Overdue Payments
if the Note Holder Itas not received the full amount of any monthly payment by the end of Fifteen calendar days
after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 4.000 9'0 of
my overdue payment. {will pay this late charge promptly but only once on each late payment.
{B) Default
If I do not pay the full amount of each monthly payment on rite date it is due, I will be in default.
(C) Notice of Default
If I am in default, the Note Holder may send me a written notice telling me that if l do not pay the overdue amount by a
certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all
the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or
delivered by other means.
(D) No Waiver By Note Holder
Even if, at a time when I ant in default, the Note Holder does not require me to pay immediately in full as described
above, the Note Holder will aril! have the tight to do so if [ am in default at a later time.
(E) Payment of Note Holder's Coals and Expenses
If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to
be paid back by me for all of its costs and expenses in enforcing this Note to rite extent not prohibited by applicable law. Those
expenses include, for example, reasonable attorneys' fees.
7. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by
delivering it or by mailing it by first class mail to me al the Property Address above or at a different address if 1 give the Note
Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first
class mail to the Note Holder at the address stated in Section 3(A} above or at a different address if I am given a notice of that
different address.
S. OBLIGATIONS OF PERSONS UNDER 'I'RIS NOTE
[f more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in
this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is
also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety
or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights
under this Note against each person individually or against all of us together. This means that any one of us may be required to
pay all of the amounts owed under this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor.
"Presentment" means the right to require the Note Holder to demand paytrtertt of amounts due. "Notice of Dishonor" means the
right to require the Note Holder to give notice to other persons that amounts due have not been paid.
rro~m 3200
VMP®-5(i1PAl 50707) yaps 2 of 3 ~Mt4b:
10. AGLONGE TO THIS NOTE
If ~n allonge providing Cor payment adjustments or for any other supplemental information is executed by the Borrower
together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of
this Note as if the allonge were a part of this Note. [Check applicable boa]
^ Graduated Payment Aloonge ~ ^ Other [Specify]
11. UNIFORM SECURED NOTE
This Note is a uniform instrutt~rtt with limited variations in some jurisdictions. In addition to the protections given to the
Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security instrument"), dated the same date as
this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this
Note. That Security Instrument describes how and under what conditions 1 may be required to make immediate payment in full
of all amounts I owe under this Note. Some of those conditions are described as follows:
Regulations (38 C.F.R. Pan 36) issued under the Department of Veterans Affairs ("VA") Guaranteed Loan
Authority (38 U.S.C. Chapter 37) and in effect on the date of loan closing shall govern the rights, duties and
liabilities of the parties to this loan and any provisions of this Nvte which are inconsistent with such
regulations are hereby amended and supplemented to conform thereto.
This is a contract under seal and may be enforced under 42 PA. C.S. Section 5529(b).
WITNESS THE HAND(S) AND
Hunter
(Seal)
-Borrower
-(~)
-Burrower
(~)
_ -Borrower
~'
^ Other [Specify]
_, (Seal)
-Borrower
(Seal)
-Borrower
PAY TO THE ORDER OF:
WELLS FARGO BANK, N.A.
WITHOUT RECOURSE, MST 8<a1NK
couRS~
PAY TO THE SIGNt=tgnrrdureFL .. _ _. _ J .
w>=t. FARGO ASK. "•A• NAME: ERIN L. DOERFI,Ea
sy ___=~~~M. swanso~~~^ TITLE: ASSISTANT VIC~ PRESI
s~ DENT
Assistant Vice President
_-
VMP®-5ti(PA) ~o~o~t
OF THE UNDERSIGNED.
Psgs 3 of 3
(Seal)
-Borrower
_ (Seal}
-Borrower
/Sign Original Onlyl
Form 3200 1101
Exhibit "B"
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon
erected, situate in the Township of East Pennsboro, County of Cumberland, and Commonwealth
of Pennsylvania, bounded and described in accordance with a survey made by D.P.
Raffensperger, Registered Surveyor, on July 26, 1956, as follows, to wit:
BEGINNING at a point on the northerly line of Brentwood Road, at the westerly line of
Lot No. 11, Block "G" on the Plan hereinafter mentioned, which point is at the distance of three
hundred fifty-three and seventy one-one hundredths feet (353.71') westwardly of the intersection
of Brentwood Road with Brier Road; thence along the northerly line of Brentwood Road south
fifty-four degrees, sixteen minutes west, seventy-five feet (S. 45° -16 min. W. 75') to a point at
the easterly line of Lot No. 13, Block "G"; thence along said line north thirty-five degrees, forty-
four minutes west one hundred three and forty-two one-hundredths feet (N. 35° -44 min. W.
103.42 `) to a point on the easterly line of Lot No. 14, Block "G"; thence along said line, north
five degrees, twenty-five minutes east sixty feet (N. 5 degrees - 25 min. E. 60 feet) to a point on
the southerly line of Lot No. 2, Block "G"; thence along said line north fifty-one degrees, fifty
minutes east thirty-five and fifty-eight one-hundredths feet (N. 51° - 50 min. E. 35.58') to a point
on the westerly line of Lot No. 11, Block "G"; thence along said line south thirty-five degrees,
forty-four minutes east, one hundred fifty feet (S. 35° - 44 min. E. 150') to the first mentioned
point and place of BEGINNING.
PROPERTY ADDRESS: 2 BRENTWOOD ROAD, CAMP HII.L, PA 17011-2503
PARCEL # 09-19-1590-030.
File #: 312806
VERIFICATION
Jasmin McLean, hereby states that he/the js Vice President Loan Documentation of
WELLS FARGO BANK, N.A., plaintiff in this matter, that he/p~. J s authorized to make this
Verification, and verify that the statements made in the foregoing Civil~Action in Mortgage
Foreclosure are true and correct to the best of his er 'nformation and belief. The
undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S.
Sec. 4904 relating to unsworn falsification to authorities.
Name: in McLean
Title: Vice President Loan Documentation
Company: Wells Fargo Bank, N.A.
Date: 01/28/2013
086-PA-V2 File # 312806
FORM l
WELLS FARGO BANK, N.A.
Plaintiff(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA.
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MORTGAGE FORECL(TRE ~ '-
vs.
JOSEPH HUNTER JACOBS
Defendant(s)
NOTICE OF RESIDENTIAL
DIVERSION PROGRAM -~; ~ ~"
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference.
First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 2439400
extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you.
Once you have been appointed a legal representative, you must promptly meet with that legal representative within
twenty (20) days of the appointment date. During that meeting, you must provide the lega>representative with all
requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal
representative complete a financial worksheet in the format attached hereto, the legal representative will prg~are and a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the
service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your
lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a
conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal
representative. However, you must provide your lawyer with all requested financial information so that a loan resibution
proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached
hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed
within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable
arguments with your lenderbefore the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
2fs
Date
Yohn Michael Kolesnik, Esq., Id.
No.308877
Attorney for Plaintiff
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)
assistance?
Yes ^ No ^
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ^ No ^
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender and lender's loan servicing
company:
Lender's Contact (Name):
Phone:
Servicing Company (Name):
Contact: Phone:
I/We, ,authorize the above named
to use/refer this information to my lender/servicer for the sole purpose of evaluating my
financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to
use the counseling services provided by the above named
Borrower Signature Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and lender's
counsel:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation (hardship
letter)
6. Listing agreement (if property is currently on the market)
FORM 2
Date
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to determine
possible options while working with your counseling agency. Please provide the following information to
the best of your knowledge:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different):
City:
Phone Numbers:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
First Mortgage Lender:
Type of Loan:
Loan Number:
State: Zip:
Yes ^ No ^ Listing date: Price: $
Realtor Phone:
Yes ^ No ^
State: Zip:
Home: Office:
Cell: Other:
How long?
Home: Office:
Cell: Other:
State: Zip:
How long?
Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $
Date of Last Payment:
Included Taxes & Insurance:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ^ No ^
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile # 1; Model:
Amount owed: Value:
Automobile #2: Model:
Amount owed: Value:
Other tran~ortation (automobiles boats, motorcvclesl: Model:
Year: Amount owed: Value_
Monthly Income
Name of Employers:
l . Monthly Gross Monthly Net
2. Monthly Gross Monthly Net
3, Monthly Gross Monthly Net
Additional Income Description (not wages):
1, monthly amount:
2, monthly amount:
Borrower Pay Days:
Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mort a e Food
2" Mort a e Utilities
Car Pa ment s Condo/Nei h. Fees
Auto Insurance Med. not covered
Auto fuel/re airs Other ro a ment
Install. Loan Pa ment Cable TV
Child Su ort/Alim. S endin Mone
Da /Child Care/Tuft. Other Ex enses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ^ No ^
If yes, please provide the following information:
Counseling Agency:
Year:
Year:
Counselor:
Phone (Office): Fax:
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 #: 312806
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103 1
215-563-7000 `2
MCD "
WELLS FARGO BANK,N.A. Court of Common Pleas =:�a °v ,
Plaintiff )r-
-<>
Civil Division r—
vs A n :;,
CUMBERLAND County c _ c-)r-Y',
JOSEPH HUNTER JACOBS D
Defendant No. 13-623-CIVIL -<
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 rem judgment Satisfied and the action Discontinued and Ended.
❑Please Va/ to t Judgment entered.
Date: ` PHEL HALLIN LLP
By:
Joseph A.Desso e,Esq.,Id. No.200479
Attorney for Plaintiff
PHS#312806
Phelan Hallinan,LLP Attorney for Plaintiff
1617 JFK Boulevard, Suite 1.400
One Penn Center Plaza
Philadelphia,PA 1.9103
21.5-563-7000
WELLS FARGO BANK, N.A. Court of Common Pleas
Plaintiff Civil Division
V. CUMBERLAND County
JOSEPH HUNTER JACOBS No. 13-623-CIVIL
Defendant PHS#312806
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:
JOSEPH HUNTER JACOBS
2 BRENTWOOD ROAD
CAMP HIL7W12 11-2503
Date: 7 P LAN HAL AN,L P
By:
Joseph A.D ss e,E .,Id. No.200479
Atto y for Plaintiff