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Home My WebLink About00-07986 ~ , 'I,~,,,,,,~ ~ ~ . r FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (?l~) ";1-7000 ,..., ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION PRINCIPAL RESIDENTIAL MORTGAGE, INe. 711 HIGH STREET DES MOINES, IA 50392-0780 Plaintiff TERM NO. (J1). 79f'&, ~ ~ v. CUMBERLAND COUNTY GINGER R. RAMSEY 100 NORTH 17TH STREET CAMP HILL, PA 17011 Defendant( s) CTVTT, ACTION - LAW COMPI ,A TNT IN MORTGAGE FORECI,OSTTRE NOTTCE ,...,. **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR TTTA T PURPOSE. IF YOU HAVE PREVTOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ,... Loan #: 13682653 .. - ~ 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INe. 711 HIGH STREET DES MOINES, IA 50392-0780 .,..", 2. The narne(s) and last known address(es) of the Defendant(s) are: GINGER R. RAMSEY 100 NORTH 17TH STREET CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/23/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1554, Page 644. By Assignment of Mortgage recorded, 7/1/99 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Book No. 618, Page 16. 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 7/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. , "... ft,.. ." ~. - '. -~ !': . , ~- 1 ,~ ", 6. The following amounts are due on the mortgage: Principal Balance $116,778.98 Interest 3,449.60 6/1/00 through 11/1/00 (Per Diem $22.40) Attorney's Fees 4,000.00 Cumulative Late Charges 176.62 6/23/99 to 11/1/00 Cost of Suit and Title Search 5.ill.lli1 Subtotal $124,955.20 Escrow Credit 0.00 Deficit 2.82.3.6 Subtotal !I; n? 11i ,.".,- TOTAL $125,237.56 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $125,237.56, together with interest from 11/1/00 at the rate of $22.40 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ?-'~"?-~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff , t".,. "'-;-;~... -I ,"" ,. j i j =~f'~ ~LL THAT CERTAZN traa~ of ~and w~~h ~mprovements t:he Borough of Camp H.1.~.l, Cumber1and County. descr~bed as fo11owSI thereon erected s~~uote in Pennsy1.van1.a, boundad and SEGINN%NG at ~he Northwest corner o~ Wa1nut and ~7th Streets (former~y Long St~eee); tnence Westward~y a10ng Wa1nut Street:, gO.9 feet to a corner of 1and now O~ former~y o~ C1srk Ba~r; thence No~hwerd~y a10ng se~Q 1and, 98.02 feet to a po~nt: thence Eastwara1y a10ng 1and now or former1y of Erv1n E. Boyer, 90.00 feet mo~e or ~ess~ to 17th Street; ~hence Southward1y a10ng the Western 1ine of 17th Street, 110.8 feet to the p1ace o~ BEGXNN~NG. BEING ~mprovea ~1th a sLngle lOne story briok dwe11ing house known as No. 100 North 17th Stre~t, Camp H1.1~, Pennsy~van~a. BEING the same prem~ses wh~eh R. Gregory Fo~k and E~~en G. ~o1k, h1S w~fe, by the.1r deed elated. January 29, 1996 and rscordeCl in 1:he Cumber.tand County Recorder of Deeds O~~~Qe ~n eook ~34, Page 442, granted and oonveyed unto Sl~en G. FO~k, Grantor here~n. OilU~ 202 PAc,i142 = """,' . > VERlFlCA TION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this rnatter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the tirne allowed for the filing of the pleading, that he is authorized to make this verification, and that the staternents rnade in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification frorn Plaintiff as soon as it is received by counsel. 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. ~C-}~ DATE: If /7 )0lJ / I ;~!UIIJ "" . I ,~ . , . I \ r,. ~~ ~ r ~ ( '- "- (:> '" ~ '" '6' ":l I:;:; -.0 . " -~.. lj'~ .<.^~"' ~~-. - '~""'''>"''-'''-''' "=~ ., () a c} c q s: "',-j -~ -00]- 2.'5 n1n1 2:n ""~:: Z<;"'. -,. (f) ",,-':~ Go -~-! -<L~ (::c - c~.~ p :t... :I_' 20 (c] )-:>0(:-+ .. c s..? ,-n '-,/' ;::~ --'l =<! ':..!.) j:j 'D ..< - I r ~ iT. ','c..' , . ~ ~ 1 .. -~ -e:: ~'\ 0\ 0 d (0 ~ c t r -:~""""""!tiftllil~"I!f\~.!:I!l!;~I!1!'II,,",,~l'lR-~lf~'''f"'''''J:~''-:<W~_',j''';~~!f't1*~:~",,'-'t(...,,","''""'!'i'-~~!llii'','iN_!ijl;y~n!~~~I~ .~,{ . FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTAL MORTGAGE, INC. COURT OF COMMON PLEAS PLAINTIFF vs. CUMBERLAND COUNTY No. 00-7986 GINGER R. RAMSEY DEFENDANT PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. Date: December 1, 2000 f~ ~'l/' FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff '1:::"';;\11 2~, ,. .~ ~. -- , ,. VERIFICATION VICKIE JAKSICH hereby states that she is MANAGER OF FORECLOSURE of PRINCIPAL RESIDENTIAL MORTGAGE, INC mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information 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. ,- \J~ DATE: /2-/ -Ot) ',"".~." r--~ , < '1 "' SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-07986 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS RAMSEY GINGER R R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT RAMSEY GINGER R but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , RAMSEY GINGER R DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, DID NOT RECEIVE ADDL INFO FROM JASON RICCO PRIOR TO PXPIRATION DATE OF 12/12(00 Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 9.30 5.00 10.00 .00 42.30 ~~ Sheriff of Cumberland County FEDERMAN & PHELAN 01/08/2001 Sworn and subscribed to before me this /6 ~ day OfC;Luh'i :h-u( A.D. ~O 'lvi,PII-'/ #1 Pro.. 0 otary / i<;,.,_, r - FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (?1~) ~1i1-7000 t. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DNISION PRINCIPAL RESIDENTIAL MORTGAGE, INe. 711 HIGH STREET DES MOINES, IA 50392-0780 TERM Plaintiff NO. 0-0 - '7'1 pc;, ~ -- 11"...... v. CUMBERLAND COUNTY GINGER R. RAMSEY 100 NORTH 17TH STREET CAMP HILL, PA 17011 Defendant( s) CIVIl, ACTTON - I ,A W COMPI ,A TNT IN MORTGAGF, FORF,CT ,OSJTRF, NOTTCE t. **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. We hereby certify the ",ithili to !:>e a true and correct cr:::py ofthe Of1dn!\! Clad of re,:ord '"E.'O-' ,..,..,'.... "\j AUD p. HELAN ,('"=' ~hl.'Ii'j,1..d.. 1"'4. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 t. ~~ ~ereby certify the WI.tun to be a true and c~rr.ect ccpy of the orlgm~~ med of record FEDERn,iAN AND PHELAN Loan #: 13682653 TRUE COPY FROM RECORD In i8Sllmony Whereof, I here unto set my MOll and. the seal. of said ~1sI8. Pa. T1lls /3()/~Yo~; . Prothonotary '1'1 r jilf.l, ~ ~ .. 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 ,. 2. The name(s) and last known address(es) of the Defendant(s) are: GINGER R. RAMSEY 100 NORTH 17TH STREET CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/23/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROAD VIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1554, Page 644. By Assignment of Mortgage recorded, 711/99 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Book No. 618, Page 16. 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 7/1100 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. ,.. ,., ~~'m..""'~, ~, " , _ , .' 6. The following amounts are due on the mortgage: Principal Balance $116,778.98 Interest 3,449.60 6/1/00 through 11/1/00 (per Diem $22.40) Attorney's Fees 4,000.00 Cumulative Late Charges. 176.62 6/23/99 to 1111/00 Cost of Suit and Title Search ill..Oll Subtotal $124,955.20 Escrow Credit 0.00 Deficit 282..1ii Subtotal ,!;?R? 10 .' TOTAL $125,237.56 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of $125,237.56, together with interest from 11/1/00 at the rate of $22.40 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ...J.sl. FT~nk Fp.np.rm:m FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff .- f .,~ ; . I ',- -p, ." ALL THAT CERTAIN trac~ of ~and wi~h ~mprovements 1:1"u, Borough of camp Hj,l.l.~ Cumberl.anCl Count::y~ deser~bQd as fo11ows; thereon erected S~t::uote 1n Pennsyl.van.1.a, bounded and B~GINN%NG at ~he Nor~hwe.t corner o~ Wa1nut and 17th Streets (former1y Long s~reet::): thence Westwardl.y a~ong Wa~nut:: Street::, 90.9 feet to 0 CQrner of 1and n~w or formerl.y Q~ C1ark Ba.1.r; thence NO~hwsrd1y a10ng sa~d 1and, 98.02 feet ta a point: ~henQ. Sastward1Y a10ng 1and now O~ formerly of Ervin E. Soyer, 90_00 feet mora or loess. to 17th Street; thence Southward1y al.ong the Western 1~ne of 17th Stree~, 1.10.8 faet to the p1ace o~ BEGXNNZNG. aSING tmproved w~th a 9~ng~e one story brick dwel.l.~ng house known as No. ~OO North 17th Street, Camp Hi1.1~ Pennsy~van~a~ a~ING ehe same prem~se$ wh~ch R. Gregory Fo~k and E22en G. Fo~k, his w~~e, by 1:t'le.1r deed <lat:ecS. Janua:y 29, 1996 ana racordea i.n 'the Cumberl.and County R~corder o~ Deeds O~~~QG ~n Book 134, page 442, granted and conveyed unto S~len G. FO~k, Grantor herei.n. Quu~ 202 PAc,i:142 m________ . VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification frorn Plaintiff as soon as it is received by counsel. The undersigned understands that this staternent is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ; . I , ~C- },;J7D~; . DATE: 1J/7/OV / / "-~"'1~ '. -. ~,,- -~I\!jil!;lt;;!'Ni1l-...;l:l"tl;ioo[;<~l~',.,,,,,,-_,,j-". -. ,.; * ;"1."" 'o-:"~~li,.'_"'-'_""'''''' ,"""""",,,,",,_ ,>;, ,It,,:) ~=,'I,. Ji';=;:.J :":~.:1 'B;:;; ~ t?>:n1 U.! I,.w ~_,., _'_^.~:" ".._,N _.. ,~~O A '"-ii,t", .-"",-.!' _"'-"i">''''''"L@'',b!"d&-!f'll~",''-li<bt~MHd!_'!i;-.;di~ti!~''''''''iW1I'!\I'_'oill1..,iiI:i!I;\!~~;W;~1ml!ll;~.....L"ft~0>I1!i. ~~ ~'~,' ~ ~ ~ .. FEDERMAN AND PHELAN, LLP BY: FRANCIS S. HALLINAN Identification No. 62695 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Principal Residential Mortgage, Inc. Plaintiff ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division v. Cumberland County Ginger R. Ramsey Defendant No. 00-7986 PRAECIPE TO THE PROTHONOTARY: Please mark the above referenced case Discontinued and Ended without prejudice. Please mark the above referenced case Settled, Discontinued and Ended, Please mark Judgments satisfied and the Action settled, discontinued and ended, Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. X Please withdraw the complaint and mark the action discontinued and ended without prejudice. Date:~ ~"cLi r fl-dt. Francis S. Hallinan, Esquire Attorney for Plaintiff 1; "I'" ,~ , .. - "'~ -. I i. ~"'"'~- ~J~OlI'i'~_.~~JI!I-_ ,. . ~,.--".-,~-~- ~~ ...~ ,....> {:~ c;;:;;> ...r.;;- 1'</ " ., '~"; r",,,.'J ,< l_l'~~~~il't~~'1'm;r!;H)!''';l"-"'",,",)lm\''''''B:mw:~~')!!l:~~~!\<'WJ..P:Jl!P!*,,m::~r,~~1~