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Home My WebLink About14-7097 Supreme Court of Pennsylvania Court-.2 i� fi Pleas For Prothonotary Use Only: d'V`irc,o,*ef,S,,h,eet CUMBER"_X'N' -D'-0 County Docket No: The information collected on this form is used solely for court administration purposes. This fibrin does not supplement or re lace thefiling and service ofpleadings or other papers as required by law or rules o court. ourt.—_ Commencement of Action: S 0 Complaint 0 Writ of Summons 0 Petition E 0 Transfer from Another Jurisdiction 0 Declaration of Taking C Lead Plaintiff's Name: CITIFINANCIAL SERVICING Lead Defendant's Name: KENNETH L. KEITER T LLC I I Are money damages requested? El Yes Z No Dollar Amount Requested: ❑within arbitration limits 0 1 (Check one) 0 outside arbitration limits N Is this a Class Action Suit? El Yes FX1 No Is this an MDJ Appeal? F1 Yes 91 No A Name of Plaintiff/Appellant's Attorney: Kenya Bates,Esq.,Id.No.203664,Phelan Hallinan,LL 0 Check here if you have no attorney(are a Self-Represented (Pro Se) Litigant) Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT o not include Judgments) CIVIL APPEALS 0 Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment F1 Motor Vehicle 0 Debt Collection: Other 0 Board of Elections 0 Nuisance 0 Dept.of Transportation 0 Premises Liability 171 Statutory Appeal: Other 0 Product Liability(does not S include mass tort) 0 Employment Dispute: 0 Slander/Libel/Defamation Discrimination E 0 Other: 0 Employment Dispute:Other 0 Zoning Board C 0 Other: T I MASS TORT 11 Other: 0 C1 Asbestos N 0 Tobacco 0 Toxic Tort-DES •Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS •Toxic Waste 0 Ejectment 0 Common Law/Statutory Arbitration B 0 Other: 0 Eminent Domain/Condemnation 0 Declaratory Judgment 0 Ground Rent 0 Mandamus n Landlord/Tenant Dispute 0 Non-Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY C3 Mortgage Foreclosure: Commercial 0 Quo Warranto •Dental 0 Partition 0 Replevin • Legal 0 Quiet Title 0 Other: •Medical 0 Other: 0 Other Professional: Pa.R.CP. 205.5 Updated 0110112011 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 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 (800)990-9108 File#: 952363 PHELAN HALLINAN, LLP Kenya Bates,Esq.,Id.No.203664 -, ;,, F,_ 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ,., ATTORNEY FOR PLAINTIFF 3 ,3, Philadelphia,PA 19103 _" _< ,',; . kenya.bates@phelanhallinan.com 215-563-7000 CITIFINANCIAL SERVICING LLC 6400 LAS COLINAS BLVD. COURT OF COMMON PLEAS IRVING, TX 75039 CIVIL DIVISION Plaintiff V. TERM KENNETH L. KEITER, Individually and in his capacity NO. as Heir of JOYCE C. KEITER, Deceased 30 CARLISLE ROAD CUMBERLAND COUNTY NEWVILLE, PA 17241-9703 CONNIE E. KEITER 28 CARLISLE ROAD NEWVILLE, PA 17241-9703 EDNA MARIE STONE, in her capacity as Heir of JOYCE C. KEITER, Deceased 845 KEYSTONE WAY NEWPORT, PA 17074 ROBERT W. KEITER, in his capacity as Heir of JOYCE C. KEITER, Deceased 1608 WALNUT BOTTOM ROAD NEWPORT, PA 17241 UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER JOYCE C. KEITER, DECEASED 28 CARLISLE ROAD NEWVILLE,PA 17241-9703 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File#: 952363 f� 3H51?6 1. Plaintiff is CITIFINANCIAL SERVICING LLC 6400 LAS COLINAS BLVD. IRVING, TX 75039 2. The name(s) and last known address(es) of the Defendant(s) are: KENNETH L. KEITER, Individually and in his capacity as Heir of JOYCE C. KEITER, Deceased 30 CARLISLE ROAD NEWVILLE, PA 17241-9703 CONNIE E. KEITER 28 CARLISLE ROAD NEWVILLE, PA 17241-9703 EDNA MARIE STONE, in her capacity as Heir of JOYCE C. KEITER, Deceased 845 KEYSTONE WAY NEWPORT,PA 17074 ROBERT W. KEITER, in his capacity as Heir of JOYCE C. KEITER, Deceased 1608 WALNUT BOTTOM ROAD NEWPORT, PA 17241 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER JOYCE C. KEITER, DECEASED 28 CARLISLE ROAD NEWVILLE, PA 17241-9703 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 11/03/2003 KENNETH L. KEITER, CONNIE E. KEITER, and JOYCE C. KEITER made, executed and delivered a mortgage upon the premises hereinafter described to CITIFINANCIAL SERVICES, INC. , which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1848, Page 1468. By Assignment of Mortgage recorded 10/02/2014 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Instrument No. File#: 952363 201422465.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. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/07/2013 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. 6. The following amounts are due on the mortgage as of 11/08/2014: Principal Balance $56,609.51 Interest $5,657.44 06/04/2013 through 11/08/2014 Accumulated Late Charge Balance $0.00 Escrow Advance Balance $4,764.14 TOTAL $67,031.09 7. 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. 8. 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 File#: 952363 2008, 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. 9. Mortgagor JOYCE C. KEITER died on 12/21/2011, and upon information and belief, her surviving heirs are KENNETH L. KEITER, ANNA HECKENDORN, EDNA MARIE STONE, and ROBERT W. KEITER. 10. Plaintiffs representative contacted the Register of Wills of CUMBERLAND COUNTY as well as PERRY COUTNY, and was informed that no estate has been raised on behalf of the decedent mortgagor. 11. By executed waiver, ANNA HECKENDORN waived her right to be named as a defendant in the foreclosure action. Said waiver is attached as Exhibit" A ". 12. Plaintiff hereby releases JOYCE C. KEITER, from liability for the debt secured by the mortgage. 13. Plaintiff does not hold the named Defendants, EDNA MARIE STONE and ROBERT W. KEITER,personally liable on this cause of action. This action is being brought to foreclose the interest of the said Defendants in the aforesaid real estate only, and the Defendants have been named in accordance with the requirements of Pa R.C.P. 1144(a)(2) and 20 Pa.C.S.A. § 301(b). File#: 952363 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $67,031.09,together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: Kenya Bgtes, Esq., Id. No.203664 Attorney for Plaintiff File#: 952363 VERIFICATION Monica Colter,hereby states that he/she is employed as Vice President- Document Control of CitiMortgage, Inc. Pursuant to an agreement,CitiMortgage, Inc. provides certain loan servicing activities to CitiFinancial Servicing LLC, a Delaware Iimited liability company the Plaintiff of this loan. I am authorized to execute this Verification on behalf of CitiFinancial Servicing LLC pursuant to the corporate resolutions of CitiFinancial Servicing,LLC. CITIMORTGAGE, INC., on behalf of Plaintiff in this matter is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the nest of my information and belief. I understand that this statement.is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. AFFIANT Printed: 1Monica Colter Date: x y-) r' 3, v�C/1� File#: 952363 Name: K.EITER File#: 952363 LEGAL DESCRIPTION ALL that certain tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with Boundary Survey and Final Subdivision Plan for the Estate of William B. Beam prepared by Eugene Albert Hockensmith dated May 27, 1983, a copy of which is recorded in the hereinafter named Recorder's Office in Plan Book 44, Page 1, as follows: BEGINNING at a railroad spike set in the southern line of 48 feet wide PA Route No. 641, known as Newville-Carlisle Road L. R. 21091, which railroad spike at the Place of Beginning is 90 feet East of the eastern line of 50 feet wide Union Street measured along said southern line of 48 feet wide PA Route No. 641; thence from said railroad spike at the Place of Beginning along said southern line of 48 feet wide PA Route No. 641, South 64 degrees 20 minutes 43 seconds East, a distance of 84.50 feet to a railroad spike at corner of Tract#3; thence along the dividing line between Tracts #2 and#3, which dividing line between said Tracts#2 and#3 is through Lot #35 as shown on the hereinafter mentioned Plan of Lots and which dividing line through said Lot #35 is parallel to the eastern line of Lot#36 and 24.5 feet eastwardly therefrom, South 25 degrees 42 minutes 45 seconds East, a distance of 200 feet to an iron pin on the northern line of a 20 feet wide unnamed alley; thence along the northern line of said 20 feet wide unnamed alley, South 64 degrees 20 minutes 43 seconds West, a distance of 84.50 feet to an iron pin at the dividing line between Tracts #1 and #2, which dividing line between said Tracts #1 and #2 is a line through Lot#37 and which line through said Lot#37 is a line parallel to the eastern line of Lot#38 and 40 feet eastwardly therefrom; thence by said dividing line between said Tracts #1 and#2,North 25 degrees 42 minutes 45 seconds West, a distance of 200 feet to a railroad spike on the southern line of 48 feet wide PA Route 641 at the Place of BEGINNING. THE ABOVE described tract of land is all of Tract#2 as shown on said Boundary Survey and Final Subdivision Plan for the Estate of William B. Beam, recorded as aforesaid, on which there is erected a double two-story house and other improvements, with mailing address of R. D. #4, Box 21, and Box 22,Newville, Pennsylvania 17241. THE ABOVE described tract of land includes the easternmost 10 feet of Lot#37, all of Lot#36, and the westernmost 24.5 feet of Lot#35 as shown on Big Spring Heights Plan of Lots, Extension#1, as laid out by Andrew McElwain, which Plan is recorded in the hereinafter named Recorder's Office in Plan Book 2, Page 75. THE WESTERNMOST 24.5 feet of Lot#35 and all of Lot#36 included in the above described Tract#2 are portions of the tract of land which Lillie H. Beam and W. B. Beam, her husband, by deed dated June 11, 1956, and recorded June 12, 1956, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book 'F', Volume 17, Page 149, granted and conveyed to W. B. Beam and Lillie H. Beam, husband and wife. The said Lillie H. Beam having died on January 6, 1976, title to the same remained vested by operation of law solely in her surviving spouse, W. B. Beam, also known as William B. Beam. THE EASTERNMOST 10 feet of Lot#37 included in the above described Tract#2 is the same which E. Paul Spahr and wife, by deed dated October 30, 1948, and recorded December 29, File#: 952363 1948, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book 'Y', Volume 13, Page 540,granted and conveyed to Lillie H. Beam. THE LOTS of land shown on the Big Spring Heights Plan of Lots, Extension#1, recorded in said Plan Book No. 2, Page 75, are subject to the following conditions and reservations: That they are to be used for residential purposes only. Secondly, that no building shall be erected within less than 44 feet of the curbline. Thirdly, that no structure shall be erected within less than 5 feet of the division line between the adjoining properties. PROPERTY ADDRESS: 28 CARLISLE ROAD,NEWVILLE, PA 17241-9703 PARCEL #46-20-1756-042. File#: 952363 Exhibit "A" • � � ,,, ,� �, _ ,,� `� \ ` � • '� �` � �� .� _ a � • � � � �:` � � �. �,� � • � ,� r .. F � � � � � �� , � i � � � q � !- � � `P `� .� 1 1 � � -� � ' � ` �� ` _ \ ` � � � � �.� A i ~ \ 1 � � _j , * a , � � �. � WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, KENNETH KEITER A/K/A KENNETH L. KEITER,Heir of JOYCE C. KEITER, Deceased, hereby acknowledge that I may have an ownership interest in the property located at 28 CARLISLE ROAD, NEWVILLE, PA 17241-9703,in accordance with Section 301(b) of the Pennsylvania Probate,Estates and Fiduciaries Code [20 Pa C.S.A. Section 301(b)]. I do hereby waive my right to be named as a defendant in a foreclosure action as provided by Pa.R.C.P. 1141 et seq., which may be instituted by CITIFINANCIAL SERVICING LLC, involving said property, which property was owned by the decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of said action, including but not limited to the Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. I do retain any and all rights I may have under Pennsylvania law to reinstate or otherwise payoff the underlying debt or to make any claim for excess proceeds generated by the Sheriff's sale of the mortgage premises. In the event,I, the undersigned, file a Chapter 7 or Chapter 13 bankruptcy case prior to disposition of the foreclosure action to be filed with respect to the mortgaged premises; I agree that I will not contest any motion for relief from the automatic stay, or will in the alternative, clearly indicate in my bankruptcy schedules that I am surrendering any interest in the mortgaged premises. Date: KIENNETH KEITER A/K/A KENNETH L. KEITER, Heir of JOYCE C. KEITER, Deceased WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, ANNA HECKENDORN, Heir of JOYCE C. KEITER, Deceased, hereby acknowledge that I may have an ownership interest in the property located at 28 CARLISLE ROAD, NEWVILLE, PA 17241-9703,in accordance with Section 301(b)of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. Section 301(b)]. I do hereby waive my right to be named as a defendant in a foreclosure action as provided by Pa.R.C.P. 1141 et seq., which may be instituted by CITIFINANCIAL SERVICING LLC, involving said property, which property was owned by the decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of said action, including but not limited to the Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. I do retain any and all rights I may have under Pennsylvania law to reinstate or otherwise payoff the underlying debt or to make any claim for excess proceeds generated by the Sheriff's sale of the mortgage premises. In the event, I, the undersigned,,file a Chapter 7 or Chapter 13 bankruptcy case prior to disposition of the foreclosure action to be filed with respect to the mortgaged premises; I agree that I will not contest any motion for relief from the automatic stay, or will in the alternative, clearly indicate in my bankruptcy schedules that I am surrendering any interest in the mortgaged premises. Date: /0-d /- 14 AA ANNA HECKENDORN, Heir of JOYCE C. KEITER, Deceased i Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ?ti DEC 30 A l I0:1.: `l CUMBERLAND COU': PENNSYLVANIA ryFFtCE Or THE S 1 RIFF Citifinancial Servicing LLC vs. Kenneth L Keiter (et al.) Case Number 2014-7097 SHERIFF'S RETURN OF SERVICE 12/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Kenneth L Keiter, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Perry, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 12/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Connie E Keiter, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Perry, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 12/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Edna Marie Stone, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Perry, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 12/16/2014 The requested Complaint in Mortgage Foreclosure returned by the Sheriff of Perry County, the within named Defendant Kenneth L Keiter, not found. Carl E. Nace, Sheriff, Return of Service attached to and made part of the within record. 12/16/2014 The requested Complaint in Mortgage Foreclosure returned by the Sheriff of Perry County, the within named Defendant Connie E Keiter, not found. Carl E. Nace, Sheriff, Return of Service attached to and made part of the within record. 12/16/2014 12:51 PM - The requested Complaint in Mortgage Foreclosure served by the Sheriff of Perry County upon Charles G. Stone, who accepted for Edna Marie Stone, at 845 Keystone Way, Newport, PA 17074. Carl E. Nace, Sheriff, Return of Service attached to and made part of the within record. 12/19/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Edna Marie Stone, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 28 Carlisle Road, West Pennsboro Township, Newville, PA 17241. Defendant lives in Perry County. 12/19/2014 07:50 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Connie E Keiter at 28 Carlisle Road, West Pennsboro Township, Newville, PA 17241. ON KINSLER, DEPUTY 12/19/2014 07:50 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Connie Keiter, wife, who accepted as "Adult Person in Charge" for Kenneth L Keiter at 28 Carlisle Road, West Pennsboro Township, Newville, PA 17241. SON KINSLER, DEPUTY c) CountySuite Sharia: Te'eosefi. Inc. z 12/24/2014 05:09 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Michael Keiter, brother, who accepted as "Adult Person in Charge" for Robert W Keiter at 1608 Walnut Bottom Road, Penn Township, Newville, PA 17013. L I J NIKINSLER, DEPUTY SHERIFF COST: $167.39 SO ANSWERS, December 29, 2014 RONR-R ANDERSON, SHERIFF CountySuite Sheriff, Tel_osott. Inc. Citifinancial Servicing LLC Versus Kenneth L. & Connie E. Keiter Edna M. Stone IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH No. 2014-7097 Cumberland Co. SHERIFF'S RETURN And now December 16 , 2014: Served the within name Edna M. Stone the defendants) named herin, personally at her place of residence in Centre Twp -845 Keystone Way, Newport, Perry County, PA, on December 16, 2014 at 12:51 o'clock PM by handing to Charles G. Stone, defendant's husband copy(ies) of the within Complaint in Mortgage Foreclosure and made known to him the contents thereof Sworn and subscribed to before me this /7 day of r 0/ ►_i . /_ /I /CSP MMON 41TH 1 true and attested So answers OF PENNSYLOIf1Ahonotary NOTARIAL SEAL JOY S. ZERANCE, NOTARY PUBLIC NEW BLOOMFIELD BORO., PERRY COUNTY MY COMMISSION EXPIRES MARCH 10, 2018 40140 Deputy Sheriff of Perry County SHERIFF'S RETURN In the Court of Common Pleas Of the 41st Judicial District of Pennsylvania - Perry County Branch No.: 2014-7097 Cumberland Co. Citifinancial Servicing LLC VS Kenneth L. & Connie E. Keiter 845 Keystone Way Newport, PA 17074 Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant(s) to Kenneth L. Keiter, but was unable to locate him/her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure for the above named Defendant(s) Kenneth L. Keiter at 845 Keystone Way, Newport, PA 17074. NOT FOUND. DEFENDANT LIVES IN NEWVILLE AT ADDRESS LISTED ON COMPLAINT. Sworn andsubscribed to before me this / % day of 142 (, 2014. OF PENNSYLVANIA , NOTARIAL SEAL JOY. S. ZERANCE, NOTARY PUBLIC IN,'EW BLOOMFIELD BORO., PERRY COUNTY "" COMMISSION EXPIRES MARCH 10, 2018 Sincerely, Carl E. Nace Sheriff of Perry County SHERIFF'S RETURN In the Court of Common Pleas Of the 41st Judicial District of Pennsylvania - Perry County Branch No.: 2014-7097 Cumberland Co. Citifinancial Servicing LLC VS Kenneth L. & Connie E. Keiter 845 Keystone Way Newport, PA 17074 Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant(s) to Connie E. Keiter, but was unable to locate him/her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure for the above named Defendant(s) Connie E. Keiter at 845 Keystone Way, Newport, PA 17074. NOT FOUND. DEFENDANT LIVES IN NEWVILLE AT ADDRESS LISTED ON COMPLAINT. Sworn and subscribed to before me this /7 day of1_ ' ,2014. Or ! . %/// "OI'4M a� EALTH OF PENNSYLVANIA NOTARIAL SEAL JOY S. ZERANCE, NOTARY PUBLIC ' ` EW BLOOMFIELD BORO., PERRY COUNTY 4a, COMMISSION EXPIRES MARCH 10, 2018 Sincerely, Xie Carl E. Nace Sheriff of Perry County