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UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
,1HnANDRA M.-ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadingo@udren.com
Household Finance Consumer
Discount Company
961 Weigel Drive
Elmhurst, IL 60126
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
V.
Carlos Ramos, II
Melanie S. Ramos (Mortgagor) NO.
365 Criswell Drive
Boiling Springs, PA 17007
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
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.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
puede `continuar la demanda en contra suya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisioner de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA D8MA1+iDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify
us in writing of a dispute within the 30 day period, we will obtain verification of the debt or
a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not
an admission of liability on your part. Also, upon your written request within the 30 day
period, we will provide you with the name and address of the original creditor if different from
the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
I A
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. If Plaintiff is an assignee then it
is such by virtue of the following recorded assignments:
Assignor: N/A
Assignments of Record to: N/A
Recording Date: N/A
2. Defendant (s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant (s) ,
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 365 Criswell Drive
MUNICIPALITY/TOWNSHIP/BOROUGH: Monroe Township
COUNTY: Cumberland
DATE EXECUTED: 10/06/04
DATE RECORDED; 1:0/08/04 BOOK: 1883 PAGE: 4076
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
9/11/08:
Principal of debt due 141,988.06
Unpaid Interest at 8.73%
from 3/30/08 to 9/11/08
(the per diem interest accruing on
this debt is $33.96 and that sum
should be added each day after
9/11/08) 15,015.48
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Late Charges
(monthlyy late charge of $59.79
should be added in accordance
with the terms of the note
each month after 9/11/08) 298.95
NSF Charges 100.00
Attorneyys Fees (anticipated and actual
to 5% of principal) 7,099.40
TOTAL $165,106.89
7. The attorney's fee 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 in accordance with the reduction provisions of
Act 6, if applicable.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A", and made part
hereof, and defendant(s) have failed to proceed within the time
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $165,106.89 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
UDREN LAW OFFICES, P.C.
BY: (.' LeL? Crj??L/L(i?/UiC?
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
LEGAL DESCRIPTION
ALL THAT CERTAIN TRACT OF LAND LOCATED IN MONROE TOWNSHIP,
CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED
AND DESCRIBED AS FOLLOWS:
BEGINNING AT A RAILROAD MONUMENT IN THE NORTHERLY RIGHT-OF-
WAY LINE OF THE READING RAILWAY COMPANY AT CORNER OF LAND OF
ANNIE CRISWELL; THENCE BY LANDS OF ANNIE CRISWELL, NORTH 01
DEGREES 15 MINUTES WEST, A DISTANCE OF 389.9 FEET TO A NAIL IN THE
CENTER OF A PUBLIC ROAD; THENCE CONTINUING ACROSS SAID PUBLIC
ROAD ON THE SAME COURSE A DISTANCE OF 55.6 FEET, MORE OR LESS, TO A
POINT IN THE CENTER OF THE YELLOW BREECHES CREEK; THENCE BY THE
CENTER OF THE YELLOW BREECHES CREEK, NORTH 65 DEGREES 30
MINUTES WEST, A DISTANCE OF 75 FEET, MORE OR LESS, TO A POINT;
THENCE BY LANDS OF JOHN A. GOUSE, JR., ET UX, SOUTH 24 DEGREES 30
MINUTES WEST, A DISTANCE OF 53 FEET, MORE OR LESS, TO A POINT IN THE
CENTER OF THE AFORESAID PUBLIC ROAD; THENCE BY THE SAME AND
CONTINUING ACROSS THE SAID PUBLIC ROAD ON THE SAME COURSE A
DISTANCE OF 378.9 FEET TO A STAKE IN THE NORTHERLY RIGHT-OF-WAY
LINE OF THE READING RAILROAD COMPANY; THENCE BY THE NORTHERLY
RIGHT-OF-WAY LINE OF THE READING RAILROAD COMPANY, SOUTH 72
DEGREES EAST, A DISTANCE OF 272 FEET TO A RAILROAD MONUMENT, THE
PLACE OF BEGINNING.
CONTAINING 1.70 ACRES, MORE OR LESS, AND HAVING A FRONTAGE ON THE
CENTER OF THE AFORESAID PUBLIC ROAD OF 100 FEET.
September 18, 2008
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact an attorney in your area. The local bar association may be able
to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDTTAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES
SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
OHOMEOWNERBS EMERGENCY MORTGAGE ASSISTANCE PROGRAMB EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HTPOTECA.
EXtlIBITA
Page 1 of 1
. HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER:
Carlos Ramos H
Meanie S. Ramos ___...... .... 365 Criswell Drive
Boiling Springs, PA 17007
71330400466867
Household Finance Consumer Discount Cqmpa
_HFC or BFC En ' on Mortgage
HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE FILIGiSI.F. FOR FiNANCiAi. ASSISTANCE
WHICH CAN SAVE. YOUR HOME. FROM FORFCi OCITRF AND
HELP VOIT MAKF. FiMTRF. MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE FACTO), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECi,OWRE _ Under the Act, you are entitled to a temporary
stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that
time you must arrange and attend a Oface-to-faceO meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCITR VVFMIN
THE. NEXT (30) DAVS_ IF YOU DO NOT APPLY FOR FMFROFNC•V MORTGAGR
A44TSTAN(''FYOTT WST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS
NOTTC'F. C.A T .T .FD DHOW TO C:T TR F. YOT TR MOR Tr A GR DFF e T TT Tf l, FXPT A INS HaW TO
BRLNCT YOT TR MORTGACTF. I TP TO DATE
CONSUMER CREDIT COUNSELING AGENCIES _ If you meet with one of the consumer
credit counseling agencies listed at the end of this notice, the lender may NOT take action against
you for thirty (30) days after the date of this meeting. The names, dd sses and telephone numbers
of designated consumer credit counseling agencieg for the enunly in wbinl? tt,a nm a,ty ic. lomte`1
are set forth at the end of this Nnti e. It is only necessary to schedule one face-to-face meeting.
Advise your lender immediate]] of your intentions.
APPLICATION FOR MORTGAGE. ASSISTANCE. _ Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature
of your default.) If you have tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies
listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing
Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your
Page 2 of 2
face- to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGF.NCV ACTION - Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO
COLLECT THE DEBT.
(If you have fled bankruptcy you can still apply for Emergency Mortgage Assistance.)
NATURE OF THE, DEFAULT -'The MORTGAGE debt held -by the above lender on your property
located at:
365 Criswell Drive
Boiling Springs, PA 17007
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
Monthly Payments of $1195.83 for April 30, 2008 through Angnst 30, 2008 = 55979 15
Monthly Late Charges of $59.79 for April 30, 2008 through August 30, 2008 = 5298.95
Other charges (explain/itemize): NS-"=
_TOTAL AMOUNT PAST DUE: -_-- -` - -- -?--- 0
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Dn not use if not =rplicable): BU
HOW TO CURE THE. DF.FAITI.T - You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS 5078.10 PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Pavmentc nmict he made either hysaeh, cachier'c cherkr certified check or money order made. Vayahle
and cent n•
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter: ( not nce if not aiMli ahl . l: hU
Page 3 of 3
1
IF Y011 DO NOT CiTRF. THE. DEFAULT _ If you do not cure the default within THIRTY (30) DAYS
of the date of this Notice, the lender intends to exercise its rights to accel .rate h mo+ gag debt This
means that the entire outstanding balance of this debt will be considered due immediately and you may lose
the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
fnrec_lnse ?nnn your mnrtga edprnnerty,
IF THE. MORTGAGF. IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff
to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency
before the lender begins legal proceedings against you, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against
you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed
$50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other
reasonable costs. If vnu cure the default within th THIRTY f?ll),DAY pedod, you will not h
r quired to pay a nrney'g fees.
OTHER iXNDF.R REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage. If your debt has been discharged in banlauptcy without
your having reaffirmed it, then lender cannot pursue this remedy.
RIGHT TO CURE THE. DEFAULT PRIOR TO 4HERi T'c e A r N - If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to
cure the default and prevent the cal at any time p to one hour befn th Sheritl'c Cale Yn ma a-by
na3ang the total amn n then act due,_ ph & any late or a her charges then doere^conahl attorney's fees and
cuts connected with the fn ..lncur cal and any nther cnetc connected with the Sherifr Cal ac eif
in writing by the lender and by Verfolming any other rn =uirementc under the mortgage. Curing your
default in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
EARLIEST POSSiRi E SHF.RiFF'S SAi.F. DATE - It is estimated that the earliest date that such a
Sheriff s Sale- of the mortgaged property could be held would be approximately 6 months from
the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE, iENDF.R-
Name of Lender/Servicer: HSBC Mortgage
Address: %1 Weigel Drive
Ehnhurst, IL 60126
Phone Number: --
1-888-245-9318
Fax Number: 1-630-617-7145
Contact Person: Customer Service _-
EFFECT OF SHE.Ri EN SALE - You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ARSIIMPTiON OF MORTGAGF. - You may not transfer your home to a buyer or transferee who will
assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs
are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
Page 4 of 4
.
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
Page 5 of 5
V , /
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CCCS of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
FAX (717) 541-4670
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
Community Action Comm of the Capital Region
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
FAX (717) 234-2227
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
FAX n/a
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St.
Gettysburg, PA 17325
(717) 334-1518
FAX (717) 334-8326
Page 6 of 6
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Certified Mail Provides:
¦ A mailing receipt
¦ A unique identifier for your mailpieoe
¦ A record of delivery kept by the Postal Service for two years
Important Reminders.
¦ Certified Mail may ONLY be combined with First-Class Mail* or Priority Mail.
¦ Certified Mail is not available for any class of international mail.
¦ NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For
valuables, please consider Insured or Registered Mail.
¦ For an additional fee, a Retum Receipt maybe requested to provide proof of
delivery. To obtain Return Receipt service, please complete and attach a Return
Receipt (PS Form 3811) to the article and add applicable postage to cover the
fee. Endorse mailpiece Return Receipt Requested`. To receive a fee waiver for
a duplicate return receipt, a USPSe Postmark on your Certified Mail receipt is
required.
¦ For an additional fee, delivery may be restricted to the addressee or
addressee's authorized agant, Advise the clerk or ark the mailpiece with the
endorsement "Restricted Delivery
¦ Iffle postmark on the frtified Mail receipt is desired, please present the arti-at the
post receipt is not needed, detach and waft ?It a l ??post age and ailrtffied Mail
IMPORTANT. Save this receipt and present it when making an inquiry.
PS Form 3800, August 20116 (Revimm) PSN 7630.02-000.9047
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Certified Mail Provides:
¦ A mailing receipt
¦ A unique identifier for your mailpiece
¦ A record of delivery kept by the Postal Service for two years
Important Reminders:
¦ Certified Mail may ONLY be combined with First-Class Maile or Priority Maile-
¦ Certified Mail is notavailable for any class of international mail.
¦ NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For
valuables, please consider Insured or Registered Mail.
¦ For an additional fee a Retum Receipt may be requested to provide of of
die P (P oborm 3e iu to the pt article ana service pease complete and attach a Return
F1) Endorse mailplece "Return Receipt Requested licablrye a feeowaiver foe
a duplicate return receipt, a USPS® postmark on your Certified Mail receipt is
required.
¦ For an additional fee, delivery may be restricted to the addressee or
addressee's authorized aDt. Advise the clerk or mark the mailpiece with the
endorsement "Remwotio ejlvey
¦ if a postmark on the Certified Mail receipt is desired, pplease present the arti-
cle at the post office for postmarking. If a postmark on the Certified Mail
receipt is not needed, detach and affix label with postage and mail
IMPORTANT. Save this receipt and present it when making an inquiry.
PS Form 3800, August 2008 (Reveme) PSN 753o .02_00o.9047
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V E R I F I C A T I O N
The undersigned, hereby states that he/she is the attorney for
the Plaintiff, a corporation unless designated otherwise; that
he/she--is authorized to take this Verification and does so because
of the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he/she
has personal knowledge of some of the facts averred in the
foregoing pleading; and that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge,
information and belief and the source of his information is public
records and reports of Plaintiffs agents. The undersigned
understands that this statement herein is made subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
UDREN LAW OFFICES, P.C.
BY J
Attorneys for P aintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
n
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06424 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER
VS
RAMOS CARLOS II ET AL
SHANNON K SHERTZER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
RAMOS CARLOS II the
DEFENDANT , at 0008:39 HOURS, on the 1st day of November-, 2008
at 365 CRISWELL DRIVE
BOILING SPRINGS, PA 17007
CARLOS RAMOS II
DEFENDANT
was served upon
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
18.00
6.00
.00
10.00
.00
34.00
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscibed to
before me this
day
So Answers:
R. homas Kline
11/06/2008
UDREN LAW OFFICES
By: ?, 14
Deputy Sh i f
of A. D.
• ? CASE NO: 2008-06424 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER
VS
RAMOS CARLOS II ET AL
SHANNON K SHERTZER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
RAMOS MELANIE S the
DEFENDANT , at 0008:39 HOURS, on the 1st day of November-, 2008
at 365 CRISWELL DRIVE
BOILING SPRINGS, PA 17007
by handing to
ADULT IN CHARGE
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 6.00
Service .00 01/1
Affidavit .00 -01 le
Surcharge 10.00 R. Thomas Kline
.00
16.00 11/06/2008
UDREN LAW OFFICES
Sworn and Subscibed to By:
before me this day Deputy Sheriff
of , A. D.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer :COURT OF COMMON PLEAS
Discount Company :CIVIL DIVISION
Plaintiff :Cumberland County
V.
Carlos Ramos, II :NO. 08-6424
Melanie S. Ramos (Mortgagor)
Defendant(s)
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification for the
Verification attached to the Complaint in Mortgage Foreclosure with
regard to the captioned matter.
DATED: February 10, 2009
UDREN LAW OFFICES, P.C.
Attbrn€ys_.for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
V E R I F I C A T I O N
The undersigned, an officer of the Corporation which is the
Plaintiff in the foregoing Complaint or an officer of the
Corporation which is the servicing agent of Plaintiff, and being
authorized to make this verification on behalf of the Plaintiff,
hereby verifies that the facts set forth in the foregoing Complaint
are taken from records maintained by Plaintiff in the ordinary
course of business and that those facts are true and correct to the
best of the knowledge, information and belief of the undersigned.
The undersigned understands that this statement is made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: 0
Name : pec??r ; « ti4vr,??
Title: Fdr?c?asvr? gQ?c? 1,
Company: HSBC Mortgage
Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
Loan #71330400464367
MJU #08090178-1
//3/C8
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OFFICIAL SEAL
K VYFHUIS
NOTARY PUBLIC - STATE OF ILLINOIS
MY COMMISSION EXPIRES:01/30/10
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID
STUART WINNEG, ESQUIRE - ID
LORRAINE DOYLE, ESQUIRE - ID
ALAN M. MINATO, ESQUIRE - ID
CHANDRA M. ARKEMA, ESQUIRE -
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer
Discount Company
961 Weigel Drive
Elmhurst, IL 60126
Plaintiff
V.
Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
365 Criswell Drive
Boiling Springs, PA 17007
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
Defendant(s) Carlos Ramos, II and Melanie S. Ramos (Mortgagor) for
failure to file an Answer to Plaintiff's Complaint within 20 days from
service thereof and for foreclosure and sale of the mortgaged premises,
and assess Plaintiff's damages as follows:
As set forth in Complaint $165,106.89
Interest Per Complaint 5,161.92
From 9/12/08 to 2/10/09
Late charges per Complaint 298.92
From 9/12/08 to 2/10/09
TOTAL ,$170,567.73
I hereby certify that (1) the addresses of the Plaintiff and
Defendant are as shown above, and (2) that notice has been given in
accordance with Rule 237.1, a copy of which is attached hereto.
UDREN.- P.C.
BY(
Attorneys fo Plaintiff
MARK J. UDRE IRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
DAMAGES ARE HEREBY ASSESSED AS
DATE : - /Q . ;?4 '
#04302
#45362
#34576
#75860
ID #203437
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 08-6424
INDICAT D
PRO THY
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UDPJK LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LOPJAINB DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID ##75860
CHAWRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHIMY SILL, NJ 08003
856-669-5400
Household Finance Consumer Discount
Company
Plaintiff
V.
Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
Defendant(s)
TO: Carlos Ramos, II
365 Criswell Drive
Boiling Springs, PA 17007
Date of Notice: January 30, 2009
IMPORTANT NOTICE
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 08-6424
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES
OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN
TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YO&R PROPERTY OR OTHER IMPORTANT
RIGHTS.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 AGENHES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS
AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION CASO.
DENTRO UN4TERMDINODDESDIEZR(10)NDIASEDE ESTA NOTIFICACION, ELACTRIBUNALCION SIINDE
NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA D'ICTAR
SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOA,
IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI
USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,
VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS
DEEMED TO BE A DEBT COLLECTOR AN ATTEMPT TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL B BED PURPOSE.
Stuart Winneg, Esquire
Lorraine Doyle, Esquire
Alan M. Minato, Esquire
Chandra M. Arkema, Esquire
-ouis A. Simoni, Esquire
Woodcrest Corporate center
111 Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
C.3 ry,
tom:
UDRBN LAW OFFICES, P. C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITS 200
CHERRY BILL, NJ 08003
856-669-5400
I?gQg +drgn cam
Household Finance Consumer Discount
Company
Plaintiff
V.
Carlos Ramos, II
Melanie S. Ramos ((Mortgaggor)
Defendant(s)
TO: Melanie S.. Ramos (Mortgagor)
365 Criswell Drive
Boiling Springs, PA 17007
Date of Notice: January 30, 2009
IMPORTANT NOTICE
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 08-6424
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES
OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN
TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YO6R PROPERTY OR OTHER IMPORTANT
RIGHTS.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.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE
UN TERMINO NECESIDAD DE ECODIEZ (10) MPARARECER IUSTED EN T CORTE I0 ESCUCKAR EPREUBA TRIBUNAL DfCTAR
SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS-DERECHO?,
IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI
USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE P{TEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS
DEEMED TO BE A DEBT COLLECTO ATTEMPT TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL IISED PC ; TF,AT URPOSE.
Stuart Winneg, Esquire
Lorraine Doyle, Esquire
Alan M. Minato, Esquire
Chandra M. Arkema, E-squire
...Louis A. Simoni, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
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UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. AR.KEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
Household Finance Consumer
Discount Company
961 Weigel Drive
Elmhurst, IL 60126
Plaintiff
V.
Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
365 Criswell Drive
Boiling Springs, PA 17007
Defendant(s)
STATE OF
COUNTY OF
SS
THE UNDERSIGNED being duly sworn, deposes and says that the
averments herein are based upon investigations made and records
maintained by us either as Plaintiff or as servicing agent of the
Plaintiff herein and that the above Defendant (s) are not in the
military or Naval Service of the United States of America or its
Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, , as amended, and that the age and last known residence and
employment of each Defendant are as follows:
Defendant:
Age:
Residence:
Employment:
Defendant:
Age:
Residence:
Employment:
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO.() b - Vqd?
AFFIDAVIT OF NON-MILITARY SERVICE
Carlos Ramos, II
Over 18
As captioned above
Unknown
Melanie S. Ramos
Over 18
As captioned
Unknown
Sworn to and subscribed
before me this day
Of NbO ber 2OCR .
0
(Mortgagor)
above
ame : Zw a -k-4- i L2
Title: ?orec?vsur? Sp\ZSr
Company: HSBC Mortgage
w-----
OFFICIAL SEAL
K VYFHUIS
NOTARY PUBLIC - STATE OF ILLINOIS
MY COMMISSION EXPIRES:01/30110
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer :COURT OF COMMON PLEAS
Discount Company :CIVIL DIVISION
Plaintiff :Cumberland County
V.
;MORTGAGE FORECLOSURE
Carlos Ramos, II :NO. 08-6424
Melanie S. Ramos (Mortgagor)
Defendant(s)
T0: Melanie S. Ramos (Mortgagor)
365 Criswell Drive
Boiling Springs, PA 17007
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, ou are
hereby notified that a Judgment has been entere gai in the
above proceeding as indicated below.
of o ry
X Judgment by Default
Money Ju
Judgment
Judgment
Judgment
Judgment
Judgment
3gment
in Replevin
for Possession
on Award of Arbitration
on Verdict
on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY Mark J. Udren, Esquire
At this telephone number: 856-669-5400
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer :COURT OF COMMON PLEAS
Discount Company :CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Carlos Ramos, II
Melanie S. Ramos (Mortgagor) NO. 08-6424
Defendant (s)
TO: Carlos Ramos, II
365 Criswell Drive
Boiling Springs, PA 17007
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pe sylvania, ou are
hereby notified that a Judgment has been enter ai in the
above proceeding as indicated below.
rotho y
x Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
Judgment on Award of Arbitration
Judgment on verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY Mark J. Udren, Esauire
At this telephone number: 856-669-5400
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQU'
ATTORNEY FOR PLAINTIFF
- ID #04302
- ID #45362
- ID #34576
- ID #75860
IRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer
Discount Company
Plaintiff
V.
Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
Defendant(s)
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 08-6424
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Please issue Writ of Execution in the above matter:
Amount due
Interest From 2/11/09
to Date of Sale June 10, 2009
Ongoing Per Diem of 33.96
to actual date of sale including if sale is
held at a later date
(Costs to be added) $
$170,567.73
4,075.20
UDREN LAW OFFICES, P.C.
Attorneys fo Plaintiff
MARK J. UDREN, QUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
.ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N008-6424 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Household Finance Consumer Discount Company
Plaintiff (s)
From Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
(1) You are directed to levy upon the property of the defendant (s)and to sell see legal description .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $170,567.73
L.L.$.50
Interest from 2/11/09 to date of sale June 10, 2009 ongoing per diem of $33.96 to actual date of sale
including if sale is held at a later date
Atty's Comm %
Atty Paid
Plaintiff Paid
Date: February 10, 2009
$4075.20
Due Prothy $2.00
Other Costs
rtis R. Lo thonot
(Seal)
By:
Deputy
REQUESTING PARTY:
Name Alan M. Minato, Esq.
Address: Woodcrest Corporate Center
111 Woodcrest Rd., Suite 200
Cherry Hill, NJ 08003-3620
Attorney for: Plaintiff
Telephone: 856-669-5400
Supreme Court ID No. 75860
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer :COURT OF COMMON PLEAS
Discount Company :CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Carlos Ramos, II :NO. 08-6424
Melanie S. Ramos (Mortgagor)
Defendant(s)
C E R T I F I C A T E
I hereby state that as the attorney for the Plaintiff in the
above-captioned matter and that the premises are not subject to
the provisions of Act 91 because it is:
( ) An FHA insured mortgage
( ) Non-owner occupied
( ) Vacant
( X ) Act 91 procedures have been fulfilled.
( ) Over 24 months delinquent.
This certification is made subject to the penalties of 18
Pa. C.S. Sec. 4904 relating to unsworn falsification to
authorities.
UDREN LAW OFFICES, P.C.
Attorneys aintiff
MARK J. UDREN, Q RE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer :COURT OF COMMON PLEAS
Discount Company :CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Carlos Ramos, II :NO. 08-6424
Melanie S. Ramos (Mortgagor)
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Household Finance Consumer Discount Company, Plaintiff in the
above action, by its attorney, Mark J. Udren, ESQ., sets forth as
of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at:
365 Criswell Drive, Boiling Springs, PA 17007
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Carlos Ramos, II
365 Criswell Drive
Boiling Springs, PA 17007
2. Name and address of Defendant(s) in the judgment:
Name Address
Melanie S. Ramos (Mortgagor) 365 Criswell Drive
Boiling Springs, PA 17007
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name Address
Cumberland County 1 Courthouse Sq.
Adult Probation Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage
of record:
Name Address
Household Finance 961 Weigel Drive
Consumer Discount Co. Elmhurst, IL 60126
? 5. Name and address of every other person who has any record lien
on the property:
Name Address
Monroe Twp. 1220 Boiling Springs Rd.
Municipal Authority Mechanicsburg, PA 17055
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
Name Address
Real Estate Tax Dept.
1 Courthouse Sq.,
Carlisle, PA 17013
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
13 N. Hanover St.
Carlisle, PA 17013
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale:
Name Address
Tenants/Occupants 365 Criswell Drive
Boiling Springs, PA 17007
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and
belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. sec. 4904 relating to
unsworn falsification to authorities.
DATED: February 10, 2009
UDREN LAW OFFICES, P.C.
Y:
eys -f r Plaintiff
MARK J. UDRE QUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
iC:y
G
y.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer :COURT OF COMMON PLEAS
Discount Company 'CIVIL DIVISION
Plaintiff :Cumberland County
V.
=MORTGAGE FORECLOSURE
Carlos Ramos, II :NO. 08-6424
Melanie S. Ramos (Mortgagor)
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Melanie S. Ramos (Mortgagor)
365 Criswell Drive
Boiling Springs, PA 17007
Your house (real estate) at 365 Criswell Drive
Boiling Springs, PA 17007 is scheduled to be sold at the
Sheriff's Sale on June 10, 2009, at 10:00 A.M. in the
Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA,
to enforce the court judgment of $170,567.73, obtained by
Plaintiff above (the mortgagee) against you. If the sale is
postponed, the property will be relisted for the Next Available
Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. You may find out the price bid by calling 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
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 LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
L
l 4:.? i...I
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- ? -`i"
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? i Pl,? ?3
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UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQU
ATTORNEY FOR PLAINTIFF
- ID #04302
- ID #45362
- ID #34576
- ID #75860
IRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer
Discount Company
Plaintiff
V.
Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
Defendant(s)
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 08-6424
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
PROPERTY: 365 Criswell Drive
Boiling Springs,-PA 17007
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumberland County Sheriffs Sale on June 10, 2009, at 10:00 A.M.,
at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle,
PA. Our records indicate that you may hold a mortgage or judgment
on the property which will be extinguished by the sale. You may
wish to attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date
specified by the Sheriff not later that 30 days after sale.
Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the
schedule.
ALL THAT CERTAIN TRACT OF LAND LOCATED IN MONROE TOWNSHIP,
CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED
AND DESCRIBED AS FOLLOWS:
BEGINNING AT A RAILROAD MONUMENT IN THE NORTHERLY RIGHT-OF-
WAY LINE OF THE READING RAILWAY COMPANY AT CORNER OF LAND OF
ANNIE CRISWELL; THENCE BY LANDS OF ANNIE CRISWELL, NORTH 01
DEGREES 15 MINUTES WEST, A DISTANCE OF 389.9 FEET TO A NAIL IN THE
CENTER OF A PUBLIC ROAD; THENCE CONTINUING ACROSS. SAID PUBLIC
ROAD ON THE SAME COURSE A DISTANCE OF 55.6 FEET, MORE OR LESS, TO A
POINT IN THE CENTER OF THE YELLOW BREECHES CREEK; THENCE BY THE
CENTER OF - THE YELLOW BREECHES CREEK, NORTH 65 DEGREES 30
MINUTES WEST, A DISTANCE OF 75, FEET, MORE OR LESS, TO A POINT;
THENCE BY LANDS OF JOHN A. GOUSE, JR., ET UX, SOUTH 24 DEGREES 30
MINUTES WEST, A DISTANCE OF 53 FEET, MORE OR LESS, TO A POINT IN THE
CENTER OF THE AFORESAID PUBLIC ROAD; THENCE BY THE SAME AND
CONTINUING ACROSS THE SAID PUBLIC ROAD ON THE SAME COURSE A
DISTANCE OF 378.9 FEET TO A STAKE IN THE NORTHERLY RIGHT=OF-WAY
LINE OF THE READING RAILROAD COMPANY; THENCE BY THE NORTHERLY
RIGHT-OF-WAY LINE OF THE READING RAILROAD COMPANY, SOUTH 72
DEGREES EAST, A DISTANCE OF 272 FEET TO A RAILROAD MONUMENT, THE
PLACE OF BEGINNING.
CONTAINING 1.70- ACRES, MORE OR LESS, AND RAVING A FRONTAGE ON THE
CENTER OF THE AFORESAID PUBLIC ROAD OF 100 FEET.
BEING KNOWN AS: 365 Criswell Drive, Boiling Springs, PA 17007
PROPERTY ID NO.: 22-30-2664-013
TITLE TO SAID PREMISES IS VESTED IN CARLOS RAMOS II BY DEED FROM
CARLOS RAMOS II AND CHRISTINE RAMOS, HIS WIFE DATED 6/18/1997
RECORDED 6/18/1997 IN DEED BOOK 159 PAGE 615.
N :.C.1
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-6424 Civil Term
Household Finance Consumer Discount Company
Vs
Carlos Ramos, II and Melanie S. Ramos
Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that
on February 24, 2009 at 2045 hours, he served a true copy of the within Real Estate Writ,
Notice and Description, in the above entitled action, upon the within named defendants, to
wit: Carlos Ramos, II and Melanie S. Ramos,
by making known unto Carlos Ramos, II and Melanie S. Ramos, personally, at, 365 Criswell
Drive, Boiling Springs, Cumberland County, Pennsylvania its contents and at the same time
handing to them personally the said true and correct copy of the same.
R. Thomas Kline, Sheriff, being duly sworn according to law, states this writ is
returned STAYED.
Sheriffs Costs:
Docketing $30.00
Poundage 211.90
Law Library .50
Prothonotary 2.00
Mileage 6.30
Levy 15.00
Surcharge 30.00
Share of Bills 15.43
$ 311.13 ? 410??6 9
Soo Answers, n ?
t-
,- . ?
-' 1
,
?
e ,400 --c r ?
R. Thomas Kline, Sheriff
By C\??
Real Estate Coordinator ?.?
==<
%. -? 9 V3
I .`
MARK J. WREN, ESQUIRE - ID #04302
STUART,TANNkG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer :COURT OF COMMON PLEAS
Discount Company :CIVIL DIVISION
Plaintiff :Cumberland County
UDREN LAW OFFICES P.C. ATTORNEY FOR PLAINTIFF
AFFIDAVIT PURSUANT TO RULE 3129.1
Household Finance Consumer Discount Company, Plaintiff in the
above action, by its attorney, Mark J. Udren, ESQ., sets forth as
of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at:
365 Criswell Drive, Boiling Springs, PA 17007
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Carlos Ramos, II 365 Criswell Drive
Boiling Springs, PA 17007
2. Name and address of Defendant(s) in the judgment:
Name Address
Melanie S. Ramos (Mortgagor) 365 Criswell Drive
Boiling Springs, PA 17007
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name Address
V.
Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
Defendant(s)
Cumberland County
Adult Probation
MORTGAGE FORECLOSURE
NO. 08-6424
1 Courthouse Sq.
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage
of record:
Name Address
Household Finance 961 Weigel Drive
Consumer Discount Co. Elmhurst, IL 60126
5. Name and address of every other person who has any record lien
on the property:
Name . - Address
Monroe Twp. 1220 Boiling Springs Rd.
Municipal Authority Mechanicsburg, PA 17055
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
Name Address
Real Estate Tax Dept.
1 Courthouse Sq.,
Carlisle, PA 17013
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
13 N. Hanover St.
Carlisle, PA 17013
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale:
Name Address
Tenants/Occupants 365 Criswell Drive
Boiling Springs, PA 17007
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and
belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. sec. 4904 relating to
unsworn falsification to authorities.
DATED: February 10, 2009
UDREN LAW OFFICES, P.C.
Y:
Attarney-a--f r Plaintiff
MARK J. UDRE DIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WT,NNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARREMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer :COURT OF COMMON PLEAS
Discount Company ':CIVIL DIVISION
Plaintiff ,Cumberland County
V.
;MORTGAGE FORECLOSURE
Carlos Ramos, II €NO. 08-6424
Melanie S. Ramos (Mortgagor)
Defendant (s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Carlos Ramos, II
365 Criswell Drive
Boiling Springs, PA 17007
Your house (real estate) at 365 Criswell Drive
Boiling Springs, PA 17007 is scheduled to be sold at the
Sheriff's Sale on June 10, 2009, at 10:00 A.M. in the
Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA,
to enforce the court judgment of $170,567.73, obtained by
Plaintiff above (the mortgagee) against you. If the sale is
postponed, the property will be relisted for the Next Available
Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1`- If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. You may find out the price bid by calling 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
UDREN,LAW OFFICES; P.C. ATTORNEY FOR PLAINTIFF
NIA J. UDR9N, ESQUIRE - ID #04302
`STVAT WiNNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadingsQudren.com
Household Finance Consumer =COURT OF COMMON PLEAS
Discount Company :CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Carlos Ramos, II =NO. 08-6424
Melanie S. Ramos (Mortgagor)
Defendant (s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
T0: Melanie S. Ramos (Mortgagor)
365 Criswell Drive
Boiling Springs, PA 17007
Your house (real estate) at 365 Criswell Drive
Boiling Springs, PA 17007 is scheduled to be sold at the
Sheriff's Sale on June 10, 2009, at 10:00 A.M. in the
Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA,
to enforce the court judgment of $170,567.73, obtained by
Plaintiff above (the mortgagee) against you. If the sale is
postponed, the property will be relisted for the Next Available
Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
„RIGS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. You may find out the price bid by calling 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened,. you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
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 LISTED BELOW TO
FIND OUT ADHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ALL THAT CERTAIN TRACT OF LAND LOCATED IN MONROE TOWNSHIP,
CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED
AND DESCRIBED AS FOLLOWS:
BEGINNING AT A RAILROAD MONUMENT IN THE NORTHERLY RIGHT-OF-
WAY LINE OF THE READING RAILWAY COMPANY AT CORNER OF LAND OF
ANNIE CRISWELL; THENCE BY LANDS OF ANNIE CRISWELL, NORTH .01
DEGREES 15 MINUTES WEST, A DISTANCE OF 389.9 FEET TO A NAIL IN THE
CENTER OF A PUBLIC ROAD; THENCE CONTINUING ACROSS.. SAID PUBLIC
ROAD ON THE SAME COURSE A DISTANCE OF 55.6 FEET, MORE OR LESS, TO A
POINT IN THE CENTER OF THE YELLOW BREECHES CREEK; THENCE BY THE
CENTER OF -THE YELLOW BREECHES CREEK, NORTH 65 DEGREES 30
MINUTES WEST, A DISTANCE OF 75, FEET, MORE OR LESS, TO A. POINT;
THENCE BY LANDS OF JOHN A. GOUSE; JR., ET U%, SOUTH 24 DEGREES 30
MINUTES WEST, A DISTANCE OF 53 FEET, MORE OR LESS, TO A POINT IN THE
CENTER OF THE AFORESAID PUBLIC ROAD; THENCE BY THE SAME AND
CONTINUING ACROSS THE SAID PUBLIC ROAD ON THE SAME COURSE A
DISTANCE OF 378.9 FEET TO A STAKE IN THE NORTHERLY RIGHT=OF-WAY
LINE OF THE READING RAILROAD COMPANY; THENCE BY THE NORTHERLY
RIGHT-OF-WAY LINE OF THE READING RAILROAD COMPANY, SOUTH 72
DEGREES EAST, A DISTANCE OF 272 FEET TO A RAILROAD MONUMENT, THE
PLACE OF BEGINNING.
CONTAINING 1.70- ACRES, MORE OR LESS, AND HAVING A FRONTAGE ON THE
CENTER OF THE AFORESAID PUBLIC ROAD OF 100 FEET.
BEING KNOWN AS: 365 Criswell Drive, Boiling Springs, PA 17007
PROPERTY ID NO.: 22-30-2664-013
TITLE TO SAID PREMISES IS VESTED IN CARLOS RAMOS II BY DEED FROM
CARLOS RAMOS II AND CHRISTINE RAMOS, HIS WIFE DATED 6/18/1997
RECORDED 6/18/1997 IN DEED BOOK 159 PAGE 615.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) N008-6424 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Household Finance Consumer Discount Company
Plaintiff (s)
From Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
(1) You are directed to levy upon the property of the defendant (s)and to sell see legal description .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $170,567.73 L.L.$.50
Interest from 2/11/09 to date of sale June 10, 2009 ongoing per diem of $33.96 to actual date of sale
including if sale is held at a later date $4075.20
Atty's Comm % Due Prothy $2.00
Arty Paid
Other Costs
Plaintiff Paid
Date: February 10, 2009
CA-as 6R. Long, onotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name Alan M. Minato, Esq.
Address: Woodcrest Corporate Center
111 Woodcrest Rd., Suite 200
Cherry Hill, NJ 08003-3620
Attorney for: Plaintiff
Telephone: 856-669-5400
Supreme Court ID No. 75860
Real Estate Sale # 34
On February 12, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
Monroe Township, Cumberland County, PA
Known and numbered as 365 Criswell Drive,
Boiling Springs, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: February 12, 2009
By: 1.-J aau--^ ezy?
0
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