LAW OFFICES OF PINNOLA ?5 BOMSTEIN Michael S. Bernstein, Esq, PA 1D Ne. 21328 Attorney for Plaintiff 100 South Broad Street, Suite 2126 Philadelphia, PA 19107 Tel; (.215) 592~8383 Email: mbomstein?mmaileem NORA S. JACKSON, COURT OF COMMON PLEAS Plaintiff PHILADELPHIA COUNTY ACTION LAW MARCH TERM, 2018 SAMANTHA WILCOX, et al, Defendants NO. @1595 MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT TO THE HONORABLE JUDGES OF THE SAID COURT: Plaintiff, by her attemeyl Michael S. Bernstein, hereby, moves this Honorable Court for an Grater directing service of the Complaint Upon defendant Samantha Wilcox by regular and certified mail to her last known address, by posting the eubj eet premises, and by publication, and permitting sewice of all subsequent papers upon the defendant by regular and certi?ed mail: anti in support hereof avers the follewing: 1. Plaintiff is an adult individual and former resident of the Comenwealth who now resides at 1345 Ashley Tereace, Apartment 106, Winstoanalem, Nerth Carolina. 2. Plaintiff believes and avers that defendant Samantha Wiles): is an adult individual and resident ef the Commonwealth whose address is presently unknoma. Defeiidant Wilcox has identified premises 848 Nerth 49th Sireet as her address but defeadam has, never resided at that lecatien- six? I lg Ni V. {5.59: it}, Miami}; 3?95 itemize; M1: 3% t} ?w 3, Plaintiff is the owner of premises 848 North 40?h Street, haying acquired the property by deed dated the 12th day of November, 2007 (?the original deed?) and recorded in the office of the Philadelphia Department of Records as Document No. 51825601 on the 38th of December, 2007. (A true and correce copy of the original deed is attached hereto and made part hereof as Ex. 4. Since acquiring the property, plaintiff has retained ownership and has allowed a structure on the property to he used by her son te operate the family business. 5. In making arrangements to my real estate taxes on the prepertyg plaintiff came to learn that title had apparently been transferred to defendant Wilcox by deed dated 311116: 23, 2017 (?the new deed?) and recorded in the of?ce of the Philadelphia Department: of Records as Decurnent No. 53232754 on the 30th of here; 2017. (Cepy of new deed attached as Ex. ?83? 6. The sigeeture on the new deed is not plaintiff s; it is a blatant forgery. Plaintiff?s most recent photo identi?cation card and a deed signed in 2007 Show her actual signature. (Ext attached hereto.) Her actual signamre is very different from the fraudulent signature in the new deed. 9. Plaintiff has never met defendant Wilcex. 10. Plaintiff never agreed to sell the property to Wilcox. 11. Plaintiff never received any payment in consideration of deeding the property to Wilcox 12. The eew deed recites payment of $20,000 to plaintiff. The current City assessment is $59,800. 13. Any claim by defendant to title to the procerty is invalid as behag void" ab initto. we; l4. Plaintiff believes she is entitled to relief and, pursuant to Rule 1061 plaintiff bririgs this action to quiet title in her favor. 15. Defendant Victor Miller was served on March 13, 2018. 16. Plaintiff retained the service of private investigator Diane (Iowan of Coa?dential Investigative Services, Inc, an experienced investigator, to seek to locate defendant Wilcox. Ms. (Iowan is accustomed to performing such searches. Ms. Cowan?s Af?davit of Good Faith investigation is attached hereto as Exhibit 18. Cowan?s af?davit confirms that she examined multiples data base sources. Wilcox also appears to have stolen real estate from another person and identi?ed herself as residing at another address but in fact she resides at neither address. 19. Cowarr was enable to track down the notary who notarized both fraudulent deeds. 2i}. Cowan did additional research to locate Wilcox but found so one and concluded it is even possible that the person who defrauded plaintiff was not married Samantha Wilcox? 21. The af?davit demonstrates that a good faith effort was made to locate defendant. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Rule of Civil Procedure 430(a) directing service of the Complaint by regular and certified mail addressed to the defendant 848 North 40th Street, by posting of the premises: and by publication, and permitting service of all subseqaeat papers by regular and certi?ed mail. Respectfully submitted, PMOLA 85 fr} S. Bomstein Michael St Bernstein, Esq. Attorney for Plaintiff Dated: October 103 2818 {disc it}. 3363551} psi) ?Villa; i?iilii 3345? VERIFICATION Michael S. Bernstein, states that he is attorney for the Piaintiff and that the facts set forth in the foregoing Mation are true and correct to the best of his knowledge, informatien and belief, and that this statement is made eat to the penalties of 18 Pa. USA. 4904 reiating to unsworn falsi?cation to authorities. Michael S. Bomslez?rz Michaei S. Bomsteiz: Dateci: October 103 2018 12$ 9% 3 {it "Af?darit of'DiaEe, L. Cowan Michael Esquire . 100 South Broad Street, Suite 2.226 Philadelphia PA 19l O7 Nora S.Jaekson i v. i i 4? 1 Philadelphia Coanty Court of common Pleas Docket Number: 1803~01595 Samantha Wilcox 1. 1 Diane L. Cowan state that I am President of Con?dential Investigative Services Inc. Con?dential Investigative Services is a Detective Agency licensed by the Commonwealth of and located at 235 13?h ,rStreet, Philadelphia, PA 19107. 2. At the request of Attorney Michael Bernstein I made effort to locate Wayne Grif?th or Griffin who certi?ed the residence of Samantha Wiloox in a deed dated June 23 20i7 transferring ownership of the property at 1323 North 27?h Street from Harriet Dunn and Dorcas E. Moore to Samantha Wilcox? Please see exhibit attached The narrie is not printed anywhere on the document and the signature is dif?cult to read It does appear as if the sub} eel surname is Grif?n or Griffith 3. Searches were Coadocted of ravestigative database sources. I found multiple records of individuals known as Wayne Grif?n as well as Wayne Grif?th who reside or have 111 the poet resided 111 Philadelphia Coonty Daring these searches I was unable to attribute 211131 of the individuals to the North 27?h Street property 4. Attomey Bomstein also provided a deed dated June 23 2017 pertaining to i 848 North 40th Street in Philadelphia PA. The deed indicates transfer of ownership from Nora Jackson to Samantha Wilcox Wayne Grif?th or Grif?n also signed certifying the address of the grantee Sahiantha Wilcox at 848 North 40?h Street 111 Philadelphia PA 5. In? estigation conduered confirmed that Samantha 1loox does not reside at either 848 North 40th Strees or 1323 North 27?1 Street Performing searches of investigative database sources I also found no record of aa 13d?? 1d11al known as Samantha Wilcox residing 111 Philadelphia Coamy I Jackson V. 'Wilcox Page Two 6. I One individual known as Samantha Wilcox was located who resides 111 . proximity to Philadelphia County The address reported is 602 Memoe Drive in Harleysville PA In travel to the residence to August of 2918 I made effort to contact the subject Not finding anyone at home i left a business card requesting Contact by Samantha Wiicox. A woman identifying herself as Samantha Wilcox contacted my of?ce advising she has no knowledge of the properties located at 848 North 410ih Street or 1323 North 327$h Street and does not have any knowledge of anyone by the name of Wayne Grif?n or Griffith. In addition I inquired if she was familiar with a William Ernest Johnson and she advised that she did not know this individual As a note copy of a deed dated 26 2018 transferring ownership of the property iocated at 1323 North 2'17Eh Street to Mr Johnson was provided by counsel See exhibit attached . . I did make effort to reach William Ernest Johnson 111 who would likely be I able to provide information regarding Samantha WilcOx and her contact information since he reportedly purchased the property from Ms. Wilcox however he could not-he located at 5810 Copley Road'in Philadeiphia, which is his address noted on the deed In addition I located a more current address of the subject of 54l2 Valley Street 1n Philadeiphia PA and made three efforts to reach Mr Johnson at that address however no one was found . at home Leaving a business card requesting contact Mr. Johnson did not reapond - 7 81 Dining investigation no information could he developed to confirm the identity of Samantha Wilcox or that this person exists Furthermore since there was no address mforrnation regarding Wayne Grif?th or Wayne Grif?n provided 111 the documents attached the subject could not be Located I Diane L. Cowan state that the foregoing statements made by me are true and oorreot I am aware I may be punish-ed if any of the above statements are found to he untrue paw/As Liane Cowan I Sworn to ring subscribed before - methis?; of September, 2018 $15 rEwaeeY?mm M. RGTARE AL 35% E?im 898%in Notary Poetic Cityotil?hi iadelptsie Phil aCeooty . My Commons Expires Decemberts 2W8 I . Erica Robertson ix.) ~15? 1 1 Np? 1 r-zrr 1,5131 11}, ?miniskirt-33.11