Preview
COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MARYELLEN OWENS
994 Spring Haven Road
Springfield, PA 19064 NO, CV-2021-008262
Plaintiff
Vv.
JURY TRIAL DEMANDED
SEAN LOWDEN
6 Amosland Road
Morton, PA 19070
And
BRIANA SOUTHARD
99 Riverside Avenue
Prospect Park, PA 19076
Defendants
ORDER
AND NOW, this day of »202__, after
reviewing Plaintiff's Motion for Alternative Service, it is hereby ORDERED that said Motion is
GRANTED. Plaintiff may achieve original process by serving the Defendant, Sean Lowden:
a. by regular mail;
b._ by certified mail, return receipt requested; and
¢. by posting the Complaint on the front door of 6 Amosland Road, Morton, PA
19070.
ECKELL, SPARKS, LEVY, AUERBACH, MONTE,
SLOANE, MATTHEWS & AUSLANDER, P.C.
Matthew J. Bilker, Esquire
LD. No.: 811284
300 W. State Street, Ste. 300
P.O. Box 319
Media, PA 19063
(610) 565-3700 ATTORNEY FOR
PLAINTIFF
COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MARYELLEN OWENS
994 Spring Haven Road
Springfield, PA 19064 NO. CV-2021-008262
Plaintiff
Vv.
JURY TRIAL DEMANDED
SEAN LOWDEN
6 Amosland Road.
Morton, PA 19070
And
BRIANA SOUTHARD
99 Riverside Avenue
Prospect Park, PA 19076
Defendants
PLAINTIFE’S MOTION FOR LEAVE TO SERVE ORGINAL PROCESS BY
ALTERNATIVE MEANS
1 The instant case involves personal injuries sustained by Plaintiff, Maryellen Owens,
when she was struck by a vehicle driven by Defendant, Sean Lowden, and owned by Defendant,
Briana Southard. 4 true and correct copy of Plaintiff's Writ of Summons, filed on September 29,
2021, is attached hereto as Exhibit “A.”
{1380112/1]
2. Shortly after filing suit pursuant to Pa. R.C.P. 400, Plaintiff's counsel forwarded to the
Sheriff of the County of Delaware a copy of the Writ of Summons to be served on Defendant,
Sean Lowden and Defendant, Briana Southard.
3 The Sheriff was to instructed serve Defendant, Sean Lowden, at his home located at 6
Amosland Road, Morton, PA, 19070.
4 On October 26, 2021, the Sheriff filed a return of service, indicating that Defendant, Sean.
Lowden, was not served at the identified address. A true and correct copy of the October 26,
2021 Return of Service is attached hereto as Exhibit “B.”
5 Plaintiffs’ counsel retained investigator Nora Nelle, in an attempt to properly identify the
residence of Defendant, Sean Lowden.
6 Investigator Nora Nelle contacted the Morton Post Office and confirmed that Defendant,
Sean Lowden still lives at 6 Amosland Road, Apt 311, Morton, PA. A true and correct copy of
the November J Investigative Report is attached hereto as Exhibit “C.”
7 Plaintiff's counsel reinstated the Writ of Summons in a timely manner, and attempted
service at the indicated address, and the Sheriff of Delaware County attempted, on multiple
occasions, to serve Defendant, Sean Lowden, at 6 Amosland Road, Apartment 311, Morton, PA
19070. True and correct copies of the Sheriff's Returns of Service are attached hereto as Exhibit
“——D”
8 To date, Plaintiff has been unable to effectuate service.
9 Plaintiff submits that Defendant is trying to avoid service.
10. A plaintiff may make a motion before the court for a special order directing the method
of service. Pa. R.C.P. 430(a).
il. To obtain leave for alternative service, a plaintiff must (1) show a good faith effort to
locate the person on which service is to be made; (2) undertake practical efforts to serve the
[1380112/1]
defendant under the circumstances; and (3) if the first two steps are satisfied, show that the
proposed alternative method of service is reasonably calculated to provide the defendant with
notice of the proceedings against it. Calabro v. Leiner, 464 F. Supp. 2d 470 (E.D. Pa 2006)
(applying Pennsylvania law).
12. Plaintiffs counsel has made a good faith effort to locate the Defendant.
13. It is requested that Plaintiff be allowed to serve the Defendant, Sean Lowden:
by regular mail;
by certified mail, return receipt requested; and
by posting the Complaint on the front door of 6 Amosland Road, Morton, PA
19070.
14, The proposed alternative service is reasonably calculated to provide the Defendant with
Notice of the proceedings against it.
WHEREFORE, the Plaintiffs pray permission to serve the Complaint upon Defendant by the
means outlined in Paragraph 13 above.
ECKELL, SPARKS, LEVY, AUERBACH, MONTE,
SLOANE, MATTHEWS & AUSLANDER, P.C.
BY: Lor
Matthey/J. Bilker, Esquire
Date: /2/21/2/ Attorneys for Plaintiff
[1380112/1]
EXHIBIT A
Supreme Co ennsylvania
i
Cour’ 10 Pleas
ea}
For Prothonotary Use Oalys
Ay,
Docket No: My
B County
Lys
The information collected on this form is used solely for court administration purposes. This form does uot
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
1 Complaint IE] Writ of Summons (7 Petition
S [J Transfer from Another Jurisdiction [1 Declaration of Taking
E
Lead Plaintiff's Name: Lead Defendant's Name:
Maryellen Owens Sean Lowden
Dollar Amount Requested: [lwithia arbitration limits
| Ave money damages requested? [El Yes No (check one) [Hloutside arbitration limits
Oo
N Is this a Class Action Suis? El Yes fk] No Is this an MDJ Appeal? £1 Yes EJ No
Name of Plaintif/Appellant’s Attorney: Matthew J. Bilker, Esquire
FI 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 QNIE case category that most accurately describes your
PRIMARY CASE, Ifyou ave making more than one type of claim, check the one that
you consider most important,
‘|VORT (do not include Mass Tort) CONTRACT (do not include Judgmenis) CIVIL APPEALS
1 Intentional 1 Boyer Plaintiff Administrative Agencies
TI Malicious Prosecution [1 Debt Collection: Credit Card Board of Assessment
FEI Motor Vehicle E71 Debt Collection: Other T] Board of Elections
JT] Nuisance —— Dept, of Transportation
FE] Premises Liability — Statutory Appeal: Other
TO Product Liability (dees not include soe
Fl Famployment Dispute: so ~~
amass tort)
Discrimination
Standex/Libel/ Defamation Oo Zoning Board
EF] Employment Dispute: Other
Other:
D1 other:
YO Other:
MASS TORT
£1 Asbestos
FA Tobacco
[4 Toxic Tort - DES
E71 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
FF ‘Toxic Waste tl Ejectment EJ Common Law/Statutory Arbitration
FP] Other: Emineat Domain/Condemnation FE] Declaratory Judgment
Ground Rent [J Mandamus
£1 Landlord/Tenant Dispute EE] Non-Domestic Relations
F7] Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY EJ Morlgage Foreclosure: Commercial Quo Watrante
E] Dental Partition Replevin
FE] Legal £1 Quiet Title E1other:
FE] Medical EI Other: —
[I] Other Professional:
Updated 1/1/2011
CKELL, SPARKS, LEVY, AUERBACH, MONTE,
SLOANE, MATTHEWS & AUSLANDER, P.C.
Matthew d. Bilker, Esquire
LD, No.: 311284
800 W, State Street, Ste. 300
P.O, Box 319
Media, PA 19063
(G10) 566-8700 ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MARYELLEN OWENS
994 Spring Haven Read
Springfield, PA 19064 NO.
Plaintiff
v.
JURY TRIAL DEMANDED
SEAN LOWDEN
6 Amosiand Road
Morton, PA 19070
And
BRIANA SOUTHARD
99 Riverside Avenus
Prospect Pavkk, PA 19076
Defendants
NOTICE
You have been sued in court. If you wish to defend against the claims set forth
against you in the following pages, you must take action within 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 OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
LAWYERS’ REFERRAL SERVICE
Delaware County Bar Association
836 W. Front Street
Media, PA 19063
(610) 566-6625
11346870/8)
BECKELL, SPARKS, LEVY, AUERBACH, MONTE,
SLOANE, MATTHEWS & AUSLANDER, P.C.
Matthew J, Bilker, Bequive
LD. No: 811284
800 W. State Street, Ste, 800
P.O. Box 19
Media, PA 19068
(610) 565-3700 ATTORNEY FOR PLAINTH'E
COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MARYELLEN OWENS
994 Spring Haven Road
Springfield, PA 19064 NO.
Plaintiff
v.
JURY TRIAL DEMANDED
SEAN LOWDEN
6 Amosland Road
Morton, PA 19070
And
BRIANA SOUTHARD
99 Riverside Avenue
Prospect Park, PA 19076
Defendants
PRAECIPE FOR WRIT OF SUMMONS:
TO THE OFFICE OF JUDICIAL SUPPORT:
s, and
Kindly issue a summons in the above case against the above-captioned Defendant
deliver the same to the Sheriff and to the attorney for the Plaintiff Hsted below.
HEM BOscx. ve
TTH BW J, BILIKER, ESQUIRE
Dated: __
ples [ A282 Mf
Attorney for Plaintiff
IOI IRIE AR RAR ERE R BR RR IRE IIR RTH ERI ATI IRA TD ILE BRR TORE TATED IDR TR
FHI
WRIT OF SUMMONS IN CIVIL ACTION
TOL Sean Lowden — 6 Amosland Road, Morton, PA 19070
Briana Southard-99 Riverside Avenue, Prospect Park, PA 19076
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN
ACTION AGAINST YOU,
Office of Judicial Support
Date: By:
Attested to be a true and correct copy of the original
FILED
09-20-2024 10:06AM
OTE
SE A UES
EXHIBIT B
SHERIFF'S DEPARTMENT
'
DELAWARE COUNTY
[utr
1%
201 WEST FRONT STREET, MEDIA, PENNSYLVANIA 19063 (610) 891-4296
INSTRUCTIONS FOR SERVICE OF PROCESS: You must file one
SHERIFF SERVICE instruction sheet for each defendant, Please type.
PROCESS RECEIPT, and AFFIDAVIT OF RETURN Do Not detach any copies.
TPLAINTIFF/S/ 3 CGURT NUMBER
Maryellen Owens pe | 092.0) 01
3 DEFENDANT/S/ 4 TYPE ‘OF WAIT OR COMPLAINT
Sean Lowden Writ a
e { 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVICE
Sean Lowden
6. ADDRESS (Street or AFD, Apariment No . City, Boro, Twp.. State and ZiP Code)
6 Amosland Road, Morton, PA 19070
7.ANDICATE UNUSUAL SERVICE. O REG MAIL O DEPUTIZE DPOST GOTHER
Now, 20. . |, SHERIFF OF DELAWARE COUNTY, PA, do hereby deputize the Sheriff of
County to execute this Writ and make return thereot according
to law. This deputation being made at the request and risk of the plaintiff. ‘SHERIFF GF BETAWARE COUNTY
& SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE
Deputy Sheriff
mnoee we 54 G3
Amount Pd,
Docket #
DL YS”
Page
fof? under
ICopies
NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN — Any deputy sheriff levying upon or altaching anv property
or attachment, without lability on
within writ may leave same without a watchman. in custody ‘of whomever is found in possesstan, after notilying person of tevysherilt’s
the part of such depuly of the sheriff to any plainbtt herein for any 108s, destruction or removal of any such property belore sale thereat.
9, PRINT/TYPE NAME AND ADDRESS OF ATTORNEY/ORIGINATOAR 10, TELEPHONE NUMBER 11. DATE
Matthew J, Bilker, Esq. / Eckell Sparks 610-565-3700 10/6/21
300 W. State St., #300 12. SIGNAJURE 2
Media, PA 19063 Atty ID # 311284
SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOY WRITE’BELOW THIS LINE
13 | acknowledge receipt of the weit
or complaint as indicated above
SIGNATURE of Auinonied OBCSO Deputy or WARE
—- 9392024 3O'DayS.
TO BE COMPLETED BY SHERIFF
16. Served and made known to , Defendant(s)
jon the day of 20 sat o'clock, M.,
at Street, County of Delaware,
Commonwealth of Pennsyivania, in thé manner described below:
1D Defendants) personally served. :
0 Adult family member wilh whom said Defendant(s) reside(s). Relationship is
CD Adult in charge of Defendant's resi
OD Manager/Clerk of place of lodging in which Defendant(s) reside(s).
Agent or parson in charge of Defendant's office or usual place of business.
Posted
Other
JZ al at
Be o'clock,
yey
On the day of © OF
Poller ccbl ress
Pr
Defendant not found because:
Moved 1 Unknown QNo Answer ther
Gord ple Borlerng
WY SMA
REMARKS: opt bev Bt Ory ery
IRETURNED: On A pooteeal CA m™ pier
SO ANSWER.
ay
17 AFFIRMEO and subscribed to before me this
20
16 Signatureof
ep Sherif I /
120. day of Bi Signature of Shecill 2 Oat f
23
Notary Public ft 2 SHEP OF PAP AWARE COUNTY
My COMMISSION EXPIRES,
24 | ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURRY
OF AUTHORIZED ISSUING AUTHORITY AND TITLE.
ewe “ ~~ AE ert 4 2024
eso.1-1989
Y ere
FILED
10-26-2021 03:54 PM
oFrice 0 FIARE
JUDICIAL SUPPORT
COUNTY,
ms ne
EXHIBIT C
20 Norsham Way
Vora Vehe (nvestigations Collegeville, PA 19426
Private Investigations TEL/FAX (484)-831-5723
November 1, 2021
Matthew Bilker, Esquire
Eckell, Sparks, Levy, Auerbach, Monte,
Sloane, Matthews & Auslander
300 West State Street
Suite 300
Media, PA 19063
RE Maryellen Owens-Moll
Dear Mr. Bilker,
My office was provided with a copy of a police report and asked to obtain a good address for defendant
n the report is listed
Sean Lowden. The accident occurred on October 12, 2019, and Lowden’s address o1
as 6 Amosiand Road, Morton, PA 19070.
| conducted a number of comprehensive computer database searches, and his current address is listed
as 233 Cherry Street, Sharon Hill, PA. The address was listed current as of September 2021. However,
follow up searches conducted related to that address were negative. There is an Ashley N. Shemeluk
listed at that address and she is 26 years old. However, | was unable to generate a current phone
for
number for her or the other residents of that address. | also conducted a search for phone numbers
| tried to contact the
neighbors of 233 Cherry Street, with negative results. On numerous occasions,
no fax machine
Sharon Hill Post Office by phone. No one has ever answered the phone and they have
number listed online.
of legal
Ihave mailed a “Request for change of address or hoxholder information needed for service
process” but am unsure if or when | will receive a response.
is broken, Adam
twas able to contact the Morton Post Office by phone. Although their fax machine
his email address and advised me to email my request
Nelson, the front counter clerk, provided me with
6 Amosiand Road
to him. Enclosed is the response | received indicating that Sean Lowden, for the
cali to Mr. Nelson,
address in Morton, has no change of address order on file. | followed up with another
His second response is
asking if he could positively confirm that Lowden is receiving mail at the address.
enclosed and confirms the 6 Amosland Road address, but with Apt. 314 added.
to see if this will assist the
| provided this information to your office, with the apartment number added,
from the Sharon Hill
sheriff in effecting service. | will notify your office if and when I receive a response
Post Office regarding the Cherry Street address in Sharon Hill.
seg
U,
fi
Ni 1 A Nelle
Sot 29 2021 17:58 HP LASERJET FAX pi
»
axed
1)p ob
own (FY fat
Cy, Ste ode:
HOR. CHANGE OF ADDRESS OR BOXHOLDER
INFORMATION NEEDEFOR D SERVICE OF LEGAL PROCESS
% Please fii ew address x the and stroet address (if a boxholder) for the following:
Name
Addrassy, MORLAR O Co
DPB 4 tLe
‘Noes The didine
and Fea. ea cha rage fred far: lion.
meen. ifbsewn, ond past aiee. het alavt ee repuhsfir esate iprecion
The following. inforsetion jis provided in-aogordance with 39 CPR 265 -G(G)(4) (1). There is no fee
for providing boxholdei information, The fee for providing
change of addzeas: infoumptio
is walved
n
In soordende with 39 CPR 265.6(d)(1) and correaponding Admainistrative Support Manual 352.442
1, Capacity of requester yey, arocvze enrar, ouomney orsproprasentng
sl) Feocess SECVER
2, Suaute or regulation thet empowersme to serve process
tot required whenvegimsnr fx anatorngyor a party acting
apapt a corporation acrtyyipiy se treat elie atarntey: CA PRIVATE DereeHVE ALT
3: The narags
Bf all known parties to the lidyetion SEAM eouDee’ OR and SouvHORD
4 Tes ogor in which sh sags has been ox will be heard: DEL AWC Co, Camamar FLEAS
5. The dookstor other identifying number {f one has been Issued:
5, The capacity in which thié individual is to be served ts. éyandmarvinuy FEU
7 DE AIA 7
THE SUSMISSION OF FALSA, TION EITHER (2) TO OBTAIN AND USE CHANGE CF ADDRES IF TION
BR. INFORMATION FOR.At
WITH ACTUAL OR. TROBPAENTVE LMGATION ORD TO. mAAVOID: PAYNE OF”
OF ADI CLAIDING A FINE. UP TO $10,000 OR
IMPRISONMENT OF N PMO TIAN s EARS OR BOTH CIEE 1BUSC.
Us SECTION 1601),
T Contify that the above infomation is tue and that the adress information is needed and will bs
used solely
for service of legal prdcess fh eonhumetion ‘with eotual-or prospective Iitigation.
Signetire ©
0 MONON Ud Y __
rt He Sole G8 VILLE", f4 £26
office. Leak it. es [> $9793 x
FoR Post 38Q
MY_No change ofadgen onder
an file. NEW ADDRESSOR BOXHOLDER’S NAME,
AND STREET
ADDI es
wa Movad, left fBrhantiog sddtrees, Sep
ae
No such auldress, So AZ
iya
weve
Oct 30 2021 20:07 HP LASERJET FAX pel
ce
+
ve_1ofa'y
/a |.
REQUESE FOR CHANGE OK ADDRESS OR BOXHOLDER
INFORMATION NEEDED FOR SERVICE OF LEGAL PROCKEA
Pleave Funnies th askiroso fhe Re and street adsivess (if a boxholder) for the following:
‘Nara
Addrasar, AM0s Ho20.5TOE
ponne-caid
(ose Kirosot
CFO LE Lt.
tafarinarian,
0
aa Shey cnn eRe Laat eorerqnnie dah iret,
The aera ie. provided [n-acgordunes
with 39 CER, 265.6(€y(4)Cil). There is7n0 fe
boxholder triformation. The tee for providing change of address information ls
° x prvi with 39 CPR.268.6(4)(1) and corresponding Adinintatrarive Support Manual 352. Mtn
1. Copaofty of requester (Ug. pores serwey, aatangy, pariyreprwmnthianl) Feocess SERVE we
2, Statute dr regulation. that empowers meto gerve process
Ui eaTe
(veh nequinast wiken eogieneter ts cre amporniay OF @ party ect
ssripl a agnpanttion arian pra ee:tmart cite expat, Dereey VE 27
3, ‘Thenames of all known parties to the litigation: SEGA) SouID end Shinn SQuTAARD
4, The court in whlch the cage has been or will be heard: DM AWAEGE Cd. Cannan FLEAS
5, The dooketgr other identifying nuraber if one has besn issued:
6, The capacity in which this individual is to be sorved ns. ataiworvinay :DOPE
AAA 7
THE
Sante poaMation
BORMATION aml
BOS ARNroe AN AND Usa crane cn apoRnG MrORLAATTON
i WHAN ‘THe SERN OP LEGAL CHAS IN
BLMIGATION OR(2) TO
10 AOD SANT OF
oP AUARREES TNF ‘A EINE-GP
UE TO $10,000 OR
SOR ONNENT or Te Fruits OR
0 BOTH HELE Wuee Be. SRCHON 100.
Loartity thatthe above infomation is true and thet tho address information is needed and will be
used solely for
pO”service tegel process ihn conjuaefion with aotual or prospective litigation.
@.. NORA LAY
Signetiira
MELE
aes COLL RCEVILLE,, FB te
ise LEAR BIS Ho/- 6703
(as
ASA
XYNo change ofan onderon file, NBW ARDRESS OR BOXHOLOER'S NAMB
2 oy
Moved, loft naRowapting utdrese. deine oP ay
. .7
Agk2M wt
__Ne su edie, 8
inseminations
dprmiihen oe
EXHIBIT D
i“
SHERIFF'S DEPARTMENT
DELAWARE COUNTY |
201 WEST FRONT STREET, MEDIA, PENNSYLVANIA 19063 (610) 891-4208
SHERIFF SERVICE INSTRUCTIONS FOR SERVICE OF FROCESS: You must filo one
instiuction sheet jor each defendant. Please type;
PROCESS RECEIPT, and AFFIDAVIT OF RETURN Do Not detach any copies.
PLAINTIFF/S/ 2. COURT NUMBER
ae nu
z DEFENDANTS? 4 TYPE OE Walt Oa COMPLAINT
SOAS os Ve
SERVE 5, NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC, TO SERVICE
a
GAT ESS {Streal or HFD, Apartment No. Clip. Boro, Ywp.. Slate and ZiP Goda}
AT fusos baw Bg ose BL3 have. Ba Df
INDICATE UNUSUAL SERVICE: REG MAIL GDEPUTIZE OPOST DOTHER
20, l, SHERIFF OF DELAWARE COUNTY, PA., do hereby deputize the Sheriff of
Now,
county to execute this Writ and make return thereof according
to law. This deputation being made at the request and risk of the plaintiff. ‘SHERIFF GF DECAWARE COURTY
A SPECIAL INSTRUCTIONS OA OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE
Deputy Sheritt
invoice No. tole) , 3B a
amounted, OS OS
Docket #
Page
po +
f
property under
263 ¥
NOTE ONLY APPLICABLE ON WAIT OF EXECUTION: N.B. WAIVER OF WATCHMAN — ‘Any depuly sheriff levying upon or attaching anv
within writ may leave same without a watchman, in custody of whomever is tound In posse: .ssion, alter notifying person of ievy or atlachment, without fiability on
the part of such deputy or the sherill10 any plaintiff herein for any loss, destruction or rem oval of any such property before sheriff's sale thereof.
11. DATE
9. PRINT/TYPE NAME AND ADDRESS OF ATTORNEY/ORIGINATOR 10. TELEPHONE NUMBER
4 3h fey S1fpo x3}apne ui 2h
thow Se LL 12, SIGNATURE wf ei
gee ey & Obes SOE Bs Pa 206 i
7 SPACE BELOW FOR USE OF SHERIFF ONLY —DO NOT WHITE "BELOW THIS TINE
SIGNATURE of Auihonzed DCSD Deputy or Clerk and. a 14 Date Filed 15 Expration/Hearing
date
19, | acknowledge receipt of the watt
or compiaint as Indicated above. | jd) oy Dey O4 a3 Jay
=
TO BE COMPLETED AY svienite F
16. Served and made known to Oelendant{s)
jon the Sey | 20. sat o'clock, .
lat Street, County of Delaware,
‘Commonwealth of Pennsylvania; in the manner descrioed below:
‘O Defendant(s) personally served.
O Aduil family member with whom. said Defendant(s) reside(s). Relationship is
El Adult in charge of Defendant's residence.
© Manager/Cterk of place of lod ing in which Defendants) reside(s).
ot
Ci Agent of person in charge of efendant’s 's office or usual place of business.
© Posted
©) Other T
On the be.. day of Ger 20 at ‘clock,
Defendant not found because:
C.No-Answer fA Vacant D Other fe
© Moved O Unknown
REMARKS: we per hed g ¢ ee
RETURNED:
~, SOANSWER
17. AFFIRMED and subscribed to before me this .
Signauiteol oy Ay — ® ate 7
"poco Savalas, Gh
20. day of 20 ©
23. CP D9 e074
Notary Public SHERIFF OF cnr COUNTY
MY COMMISSION EXPIRES
24 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE i? Oule Recewed
OF AUTHORIZED ISSUING AUTHORITY AND TIT
Deso-1-1989 bi te ee
2. ATTORNEY
Preview
COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYELLEN OWENS 994 Spring Haven Road Springfield, PA 19064 NO, CV-2021-008262 Plaintiff Vv. JURY TRIAL DEMANDED SEAN LOWDEN 6 Amosland Road Morton, PA 19070 And BRIANA SOUTHARD 99 Riverside Avenue Prospect Park, PA 19076 Defendants ORDER AND NOW, this day of »202__, after reviewing Plaintiff's Motion for Alternative Service, it is hereby ORDERED that said Motion is GRANTED. Plaintiff may achieve original process by serving the Defendant, Sean Lowden: a. by regular mail; b._ by certified mail, return receipt requested; and ¢. by posting the Complaint on the front door of 6 Amosland Road, Morton, PA 19070. ECKELL, SPARKS, LEVY, AUERBACH, MONTE, SLOANE, MATTHEWS & AUSLANDER, P.C. Matthew J. Bilker, Esquire LD. No.: 811284 300 W. State Street, Ste. 300 P.O. Box 319 Media, PA 19063 (610) 565-3700 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYELLEN OWENS 994 Spring Haven Road Springfield, PA 19064 NO. CV-2021-008262 Plaintiff Vv. JURY TRIAL DEMANDED SEAN LOWDEN 6 Amosland Road. Morton, PA 19070 And BRIANA SOUTHARD 99 Riverside Avenue Prospect Park, PA 19076 Defendants PLAINTIFE’S MOTION FOR LEAVE TO SERVE ORGINAL PROCESS BY ALTERNATIVE MEANS 1 The instant case involves personal injuries sustained by Plaintiff, Maryellen Owens, when she was struck by a vehicle driven by Defendant, Sean Lowden, and owned by Defendant, Briana Southard. 4 true and correct copy of Plaintiff's Writ of Summons, filed on September 29, 2021, is attached hereto as Exhibit “A.” {1380112/1] 2. Shortly after filing suit pursuant to Pa. R.C.P. 400, Plaintiff's counsel forwarded to the Sheriff of the County of Delaware a copy of the Writ of Summons to be served on Defendant, Sean Lowden and Defendant, Briana Southard. 3 The Sheriff was to instructed serve Defendant, Sean Lowden, at his home located at 6 Amosland Road, Morton, PA, 19070. 4 On October 26, 2021, the Sheriff filed a return of service, indicating that Defendant, Sean. Lowden, was not served at the identified address. A true and correct copy of the October 26, 2021 Return of Service is attached hereto as Exhibit “B.” 5 Plaintiffs’ counsel retained investigator Nora Nelle, in an attempt to properly identify the residence of Defendant, Sean Lowden. 6 Investigator Nora Nelle contacted the Morton Post Office and confirmed that Defendant, Sean Lowden still lives at 6 Amosland Road, Apt 311, Morton, PA. A true and correct copy of the November J Investigative Report is attached hereto as Exhibit “C.” 7 Plaintiff's counsel reinstated the Writ of Summons in a timely manner, and attempted service at the indicated address, and the Sheriff of Delaware County attempted, on multiple occasions, to serve Defendant, Sean Lowden, at 6 Amosland Road, Apartment 311, Morton, PA 19070. True and correct copies of the Sheriff's Returns of Service are attached hereto as Exhibit “——D” 8 To date, Plaintiff has been unable to effectuate service. 9 Plaintiff submits that Defendant is trying to avoid service. 10. A plaintiff may make a motion before the court for a special order directing the method of service. Pa. R.C.P. 430(a). il. To obtain leave for alternative service, a plaintiff must (1) show a good faith effort to locate the person on which service is to be made; (2) undertake practical efforts to serve the [1380112/1] defendant under the circumstances; and (3) if the first two steps are satisfied, show that the proposed alternative method of service is reasonably calculated to provide the defendant with notice of the proceedings against it. Calabro v. Leiner, 464 F. Supp. 2d 470 (E.D. Pa 2006) (applying Pennsylvania law). 12. Plaintiffs counsel has made a good faith effort to locate the Defendant. 13. It is requested that Plaintiff be allowed to serve the Defendant, Sean Lowden: by regular mail; by certified mail, return receipt requested; and by posting the Complaint on the front door of 6 Amosland Road, Morton, PA 19070. 14, The proposed alternative service is reasonably calculated to provide the Defendant with Notice of the proceedings against it. WHEREFORE, the Plaintiffs pray permission to serve the Complaint upon Defendant by the means outlined in Paragraph 13 above. ECKELL, SPARKS, LEVY, AUERBACH, MONTE, SLOANE, MATTHEWS & AUSLANDER, P.C. BY: Lor Matthey/J. Bilker, Esquire Date: /2/21/2/ Attorneys for Plaintiff [1380112/1] EXHIBIT A Supreme Co ennsylvania i Cour’ 10 Pleas ea} For Prothonotary Use Oalys Ay, Docket No: My B County Lys The information collected on this form is used solely for court administration purposes. This form does uot supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: 1 Complaint IE] Writ of Summons (7 Petition S [J Transfer from Another Jurisdiction [1 Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: Maryellen Owens Sean Lowden Dollar Amount Requested: [lwithia arbitration limits | Ave money damages requested? [El Yes No (check one) [Hloutside arbitration limits Oo N Is this a Class Action Suis? El Yes fk] No Is this an MDJ Appeal? £1 Yes EJ No Name of Plaintif/Appellant’s Attorney: Matthew J. Bilker, Esquire FI 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 QNIE case category that most accurately describes your PRIMARY CASE, Ifyou ave making more than one type of claim, check the one that you consider most important, ‘|VORT (do not include Mass Tort) CONTRACT (do not include Judgmenis) CIVIL APPEALS 1 Intentional 1 Boyer Plaintiff Administrative Agencies TI Malicious Prosecution [1 Debt Collection: Credit Card Board of Assessment FEI Motor Vehicle E71 Debt Collection: Other T] Board of Elections JT] Nuisance —— Dept, of Transportation FE] Premises Liability — Statutory Appeal: Other TO Product Liability (dees not include soe Fl Famployment Dispute: so ~~ amass tort) Discrimination Standex/Libel/ Defamation Oo Zoning Board EF] Employment Dispute: Other Other: D1 other: YO Other: MASS TORT £1 Asbestos FA Tobacco [4 Toxic Tort - DES E71 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS FF ‘Toxic Waste tl Ejectment EJ Common Law/Statutory Arbitration FP] Other: Emineat Domain/Condemnation FE] Declaratory Judgment Ground Rent [J Mandamus £1 Landlord/Tenant Dispute EE] Non-Domestic Relations F7] Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY EJ Morlgage Foreclosure: Commercial Quo Watrante E] Dental Partition Replevin FE] Legal £1 Quiet Title E1other: FE] Medical EI Other: — [I] Other Professional: Updated 1/1/2011 CKELL, SPARKS, LEVY, AUERBACH, MONTE, SLOANE, MATTHEWS & AUSLANDER, P.C. Matthew d. Bilker, Esquire LD, No.: 311284 800 W, State Street, Ste. 300 P.O, Box 319 Media, PA 19063 (G10) 566-8700 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYELLEN OWENS 994 Spring Haven Read Springfield, PA 19064 NO. Plaintiff v. JURY TRIAL DEMANDED SEAN LOWDEN 6 Amosiand Road Morton, PA 19070 And BRIANA SOUTHARD 99 Riverside Avenus Prospect Pavkk, PA 19076 Defendants NOTICE You have been sued in court. If you wish to defend against the claims set forth against you in the following pages, you must take action within 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS’ REFERRAL SERVICE Delaware County Bar Association 836 W. Front Street Media, PA 19063 (610) 566-6625 11346870/8) BECKELL, SPARKS, LEVY, AUERBACH, MONTE, SLOANE, MATTHEWS & AUSLANDER, P.C. Matthew J, Bilker, Bequive LD. No: 811284 800 W. State Street, Ste, 800 P.O. Box 19 Media, PA 19068 (610) 565-3700 ATTORNEY FOR PLAINTH'E COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYELLEN OWENS 994 Spring Haven Road Springfield, PA 19064 NO. Plaintiff v. JURY TRIAL DEMANDED SEAN LOWDEN 6 Amosland Road Morton, PA 19070 And BRIANA SOUTHARD 99 Riverside Avenue Prospect Park, PA 19076 Defendants PRAECIPE FOR WRIT OF SUMMONS: TO THE OFFICE OF JUDICIAL SUPPORT: s, and Kindly issue a summons in the above case against the above-captioned Defendant deliver the same to the Sheriff and to the attorney for the Plaintiff Hsted below. HEM BOscx. ve TTH BW J, BILIKER, ESQUIRE Dated: __ ples [ A282 Mf Attorney for Plaintiff IOI IRIE AR RAR ERE R BR RR IRE IIR RTH ERI ATI IRA TD ILE BRR TORE TATED IDR TR FHI WRIT OF SUMMONS IN CIVIL ACTION TOL Sean Lowden — 6 Amosland Road, Morton, PA 19070 Briana Southard-99 Riverside Avenue, Prospect Park, PA 19076 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU, Office of Judicial Support Date: By: Attested to be a true and correct copy of the original FILED 09-20-2024 10:06AM OTE SE A UES EXHIBIT B SHERIFF'S DEPARTMENT ' DELAWARE COUNTY [utr 1% 201 WEST FRONT STREET, MEDIA, PENNSYLVANIA 19063 (610) 891-4296 INSTRUCTIONS FOR SERVICE OF PROCESS: You must file one SHERIFF SERVICE instruction sheet for each defendant, Please type. PROCESS RECEIPT, and AFFIDAVIT OF RETURN Do Not detach any copies. TPLAINTIFF/S/ 3 CGURT NUMBER Maryellen Owens pe | 092.0) 01 3 DEFENDANT/S/ 4 TYPE ‘OF WAIT OR COMPLAINT Sean Lowden Writ a e { 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVICE Sean Lowden 6. ADDRESS (Street or AFD, Apariment No . City, Boro, Twp.. State and ZiP Code) 6 Amosland Road, Morton, PA 19070 7.ANDICATE UNUSUAL SERVICE. O REG MAIL O DEPUTIZE DPOST GOTHER Now, 20. . |, SHERIFF OF DELAWARE COUNTY, PA, do hereby deputize the Sheriff of County to execute this Writ and make return thereot according to law. This deputation being made at the request and risk of the plaintiff. ‘SHERIFF GF BETAWARE COUNTY & SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE Deputy Sheriff mnoee we 54 G3 Amount Pd, Docket # DL YS” Page fof? under ICopies NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN — Any deputy sheriff levying upon or altaching anv property or attachment, without lability on within writ may leave same without a watchman. in custody ‘of whomever is found in possesstan, after notilying person of tevysherilt’s the part of such depuly of the sheriff to any plainbtt herein for any 108s, destruction or removal of any such property belore sale thereat. 9, PRINT/TYPE NAME AND ADDRESS OF ATTORNEY/ORIGINATOAR 10, TELEPHONE NUMBER 11. DATE Matthew J, Bilker, Esq. / Eckell Sparks 610-565-3700 10/6/21 300 W. State St., #300 12. SIGNAJURE 2 Media, PA 19063 Atty ID # 311284 SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOY WRITE’BELOW THIS LINE 13 | acknowledge receipt of the weit or complaint as indicated above SIGNATURE of Auinonied OBCSO Deputy or WARE —- 9392024 3O'DayS. TO BE COMPLETED BY SHERIFF 16. Served and made known to , Defendant(s) jon the day of 20 sat o'clock, M., at Street, County of Delaware, Commonwealth of Pennsyivania, in thé manner described below: 1D Defendants) personally served. : 0 Adult family member wilh whom said Defendant(s) reside(s). Relationship is CD Adult in charge of Defendant's resi OD Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or parson in charge of Defendant's office or usual place of business. Posted Other JZ al at Be o'clock, yey On the day of © OF Poller ccbl ress Pr Defendant not found because: Moved 1 Unknown QNo Answer ther Gord ple Borlerng WY SMA REMARKS: opt bev Bt Ory ery IRETURNED: On A pooteeal CA m™ pier SO ANSWER. ay 17 AFFIRMEO and subscribed to before me this 20 16 Signatureof ep Sherif I / 120. day of Bi Signature of Shecill 2 Oat f 23 Notary Public ft 2 SHEP OF PAP AWARE COUNTY My COMMISSION EXPIRES, 24 | ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURRY OF AUTHORIZED ISSUING AUTHORITY AND TITLE. ewe “ ~~ AE ert 4 2024 eso.1-1989 Y ere FILED 10-26-2021 03:54 PM oFrice 0 FIARE JUDICIAL SUPPORT COUNTY, ms ne EXHIBIT C 20 Norsham Way Vora Vehe (nvestigations Collegeville, PA 19426 Private Investigations TEL/FAX (484)-831-5723 November 1, 2021 Matthew Bilker, Esquire Eckell, Sparks, Levy, Auerbach, Monte, Sloane, Matthews & Auslander 300 West State Street Suite 300 Media, PA 19063 RE Maryellen Owens-Moll Dear Mr. Bilker, My office was provided with a copy of a police report and asked to obtain a good address for defendant n the report is listed Sean Lowden. The accident occurred on October 12, 2019, and Lowden’s address o1 as 6 Amosiand Road, Morton, PA 19070. | conducted a number of comprehensive computer database searches, and his current address is listed as 233 Cherry Street, Sharon Hill, PA. The address was listed current as of September 2021. However, follow up searches conducted related to that address were negative. There is an Ashley N. Shemeluk listed at that address and she is 26 years old. However, | was unable to generate a current phone for number for her or the other residents of that address. | also conducted a search for phone numbers | tried to contact the neighbors of 233 Cherry Street, with negative results. On numerous occasions, no fax machine Sharon Hill Post Office by phone. No one has ever answered the phone and they have number listed online. of legal Ihave mailed a “Request for change of address or hoxholder information needed for service process” but am unsure if or when | will receive a response. is broken, Adam twas able to contact the Morton Post Office by phone. Although their fax machine his email address and advised me to email my request Nelson, the front counter clerk, provided me with 6 Amosiand Road to him. Enclosed is the response | received indicating that Sean Lowden, for the cali to Mr. Nelson, address in Morton, has no change of address order on file. | followed up with another His second response is asking if he could positively confirm that Lowden is receiving mail at the address. enclosed and confirms the 6 Amosland Road address, but with Apt. 314 added. to see if this will assist the | provided this information to your office, with the apartment number added, from the Sharon Hill sheriff in effecting service. | will notify your office if and when I receive a response Post Office regarding the Cherry Street address in Sharon Hill. seg U, fi Ni 1 A Nelle Sot 29 2021 17:58 HP LASERJET FAX pi » axed 1)p ob own (FY fat Cy, Ste ode: HOR. CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDEFOR D SERVICE OF LEGAL PROCESS % Please fii ew address x the and stroet address (if a boxholder) for the following: Name Addrassy, MORLAR O Co DPB 4 tLe ‘Noes The didine and Fea. ea cha rage fred far: lion. meen. ifbsewn, ond past aiee. het alavt ee repuhsfir esate iprecion The following. inforsetion jis provided in-aogordance with 39 CPR 265 -G(G)(4) (1). There is no fee for providing boxholdei information, The fee for providing change of addzeas: infoumptio is walved n In soordende with 39 CPR 265.6(d)(1) and correaponding Admainistrative Support Manual 352.442 1, Capacity of requester yey, arocvze enrar, ouomney orsproprasentng sl) Feocess SECVER 2, Suaute or regulation thet empowersme to serve process tot required whenvegimsnr fx anatorngyor a party acting apapt a corporation acrtyyipiy se treat elie atarntey: CA PRIVATE DereeHVE ALT 3: The narags Bf all known parties to the lidyetion SEAM eouDee’ OR and SouvHORD 4 Tes ogor in which sh sags has been ox will be heard: DEL AWC Co, Camamar FLEAS 5. The dookstor other identifying number {f one has been Issued: 5, The capacity in which thié individual is to be served ts. éyandmarvinuy FEU 7 DE AIA 7 THE SUSMISSION OF FALSA, TION EITHER (2) TO OBTAIN AND USE CHANGE CF ADDRES IF TION BR. INFORMATION FOR.At WITH ACTUAL OR. TROBPAENTVE LMGATION ORD TO. mAAVOID: PAYNE OF” OF ADI CLAIDING A FINE. UP TO $10,000 OR IMPRISONMENT OF N PMO TIAN s EARS OR BOTH CIEE 1BUSC. Us SECTION 1601), T Contify that the above infomation is tue and that the adress information is needed and will bs used solely for service of legal prdcess fh eonhumetion ‘with eotual-or prospective Iitigation. Signetire © 0 MONON Ud Y __ rt He Sole G8 VILLE", f4 £26 office. Leak it. es [> $9793 x FoR Post 38Q MY_No change ofadgen onder an file. NEW ADDRESSOR BOXHOLDER’S NAME, AND STREET ADDI es wa Movad, left fBrhantiog sddtrees, Sep ae No such auldress, So AZ iya weve Oct 30 2021 20:07 HP LASERJET FAX pel ce + ve_1ofa'y /a |. REQUESE FOR CHANGE OK ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCKEA Pleave Funnies th askiroso fhe Re and street adsivess (if a boxholder) for the following: ‘Nara Addrasar, AM0s Ho20.5TOE ponne-caid (ose Kirosot CFO LE Lt. tafarinarian, 0 aa Shey cnn eRe Laat eorerqnnie dah iret, The aera ie. provided [n-acgordunes with 39 CER, 265.6(€y(4)Cil). There is7n0 fe boxholder triformation. The tee for providing change of address information ls ° x prvi with 39 CPR.268.6(4)(1) and corresponding Adinintatrarive Support Manual 352. Mtn 1. Copaofty of requester (Ug. pores serwey, aatangy, pariyreprwmnthianl) Feocess SERVE we 2, Statute dr regulation. that empowers meto gerve process Ui eaTe (veh nequinast wiken eogieneter ts cre amporniay OF @ party ect ssripl a agnpanttion arian pra ee:tmart cite expat, Dereey VE 27 3, ‘Thenames of all known parties to the litigation: SEGA) SouID end Shinn SQuTAARD 4, The court in whlch the cage has been or will be heard: DM AWAEGE Cd. Cannan FLEAS 5, The dooketgr other identifying nuraber if one has besn issued: 6, The capacity in which this individual is to be sorved ns. ataiworvinay :DOPE AAA 7 THE Sante poaMation BORMATION aml BOS ARNroe AN AND Usa crane cn apoRnG MrORLAATTON i WHAN ‘THe SERN OP LEGAL CHAS IN BLMIGATION OR(2) TO 10 AOD SANT OF oP AUARREES TNF ‘A EINE-GP UE TO $10,000 OR SOR ONNENT or Te Fruits OR 0 BOTH HELE Wuee Be. SRCHON 100. Loartity thatthe above infomation is true and thet tho address information is needed and will be used solely for pO”service tegel process ihn conjuaefion with aotual or prospective litigation. @.. NORA LAY Signetiira MELE aes COLL RCEVILLE,, FB te ise LEAR BIS Ho/- 6703 (as ASA XYNo change ofan onderon file, NBW ARDRESS OR BOXHOLOER'S NAMB 2 oy Moved, loft naRowapting utdrese. deine oP ay . .7 Agk2M wt __Ne su edie, 8 inseminations dprmiihen oe EXHIBIT D i“ SHERIFF'S DEPARTMENT DELAWARE COUNTY | 201 WEST FRONT STREET, MEDIA, PENNSYLVANIA 19063 (610) 891-4208 SHERIFF SERVICE INSTRUCTIONS FOR SERVICE OF FROCESS: You must filo one instiuction sheet jor each defendant. Please type; PROCESS RECEIPT, and AFFIDAVIT OF RETURN Do Not detach any copies. PLAINTIFF/S/ 2. COURT NUMBER ae nu z DEFENDANTS? 4 TYPE OE Walt Oa COMPLAINT SOAS os Ve SERVE 5, NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC, TO SERVICE a GAT ESS {Streal or HFD, Apartment No. Clip. Boro, Ywp.. Slate and ZiP Goda} AT fusos baw Bg ose BL3 have. Ba Df INDICATE UNUSUAL SERVICE: REG MAIL GDEPUTIZE OPOST DOTHER 20, l, SHERIFF OF DELAWARE COUNTY, PA., do hereby deputize the Sheriff of Now, county to execute this Writ and make return thereof according to law. This deputation being made at the request and risk of the plaintiff. ‘SHERIFF GF DECAWARE COURTY A SPECIAL INSTRUCTIONS OA OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE Deputy Sheritt invoice No. tole) , 3B a amounted, OS OS Docket # Page po + f property under 263 ¥ NOTE ONLY APPLICABLE ON WAIT OF EXECUTION: N.B. WAIVER OF WATCHMAN — ‘Any depuly sheriff levying upon or attaching anv within writ may leave same without a watchman, in custody of whomever is tound In posse: .ssion, alter notifying person of ievy or atlachment, without fiability on the part of such deputy or the sherill10 any plaintiff herein for any loss, destruction or rem oval of any such property before sheriff's sale thereof. 11. DATE 9. PRINT/TYPE NAME AND ADDRESS OF ATTORNEY/ORIGINATOR 10. TELEPHONE NUMBER 4 3h fey S1fpo x3}apne ui 2h thow Se LL 12, SIGNATURE wf ei gee ey & Obes SOE Bs Pa 206 i 7 SPACE BELOW FOR USE OF SHERIFF ONLY —DO NOT WHITE "BELOW THIS TINE SIGNATURE of Auihonzed DCSD Deputy or Clerk and. a 14 Date Filed 15 Expration/Hearing date 19, | acknowledge receipt of the watt or compiaint as Indicated above. | jd) oy Dey O4 a3 Jay = TO BE COMPLETED AY svienite F 16. Served and made known to Oelendant{s) jon the Sey | 20. sat o'clock, . lat Street, County of Delaware, ‘Commonwealth of Pennsylvania; in the manner descrioed below: ‘O Defendant(s) personally served. O Aduil family member with whom. said Defendant(s) reside(s). Relationship is El Adult in charge of Defendant's residence. © Manager/Cterk of place of lod ing in which Defendants) reside(s). ot Ci Agent of person in charge of efendant’s 's office or usual place of business. © Posted ©) Other T On the be.. day of Ger 20 at ‘clock, Defendant not found because: C.No-Answer fA Vacant D Other fe © Moved O Unknown REMARKS: we per hed g ¢ ee RETURNED: ~, SOANSWER 17. AFFIRMED and subscribed to before me this . Signauiteol oy Ay — ® ate 7 "poco Savalas, Gh 20. day of 20 © 23. CP D9 e074 Notary Public SHERIFF OF cnr COUNTY MY COMMISSION EXPIRES 24 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE i? Oule Recewed OF AUTHORIZED ISSUING AUTHORITY AND TIT Deso-1-1989 bi te ee 2. ATTORNEY