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HomeMy WebLinkAbout09-2268Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 198815 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 V. Plaintiff DIANE M. RAMP BRANDLYN M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. Q - 4.8 (., t V LQNzwj CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 198815 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 File #: 198815 1. Plaintiff is US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: DIANE M. RAMP BRANDLYN M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 08/11/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to WELLS FARGO BANK, N.A. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1972, Page 1668. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/01/2008 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 198815 6. The following amounts are due on the mortgage: Principal Balance $300,526.62 Interest $14,079.00 10/01/2008 through 04/08/2009 (Per Diem $74.10) Attorney's Fees $1,300.00 Cumulative Late Charges $368.22 08/11/2006 to 04/08/2009 Property Inspections $30.00 Cost of Suit and Title Search 750.00 Subtotal $317,053.84 Escrow Credit $0.00 Deficit $5,285.38 Subtotal $5,285.38 TOTAL $322,339.22 7. If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or File #: 198815 Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 10. The action does not come under Act 6 of 1974 because the original mortgage amount exceeds the dollar amount provided in the statute. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $322,339.22, together with interest from 04/08/2009 at the rate of $74.10 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. PHELAN HALLINAN & SCHMIEG, LLP By. Lawrence T. Phelan, squ e Francis S. Hallinan, Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Attorneys for Plaintiff File #: 198815 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the south side of a fifty-(50) foot street known as McCormick Drive, at the corner of Lot No. 11, as shown in the hereinafter mentioned plan of lots; thence along said Lot No. 11, South 18 degrees, 24 minutes East, three hundred eighty-eight and fifty-seven one- hundredths (388.57) feet to a point in the middle of the Yellow Breeches Creek; thence on a line in said Creek, South 56 degrees West, eighty-six and fifty-two one-hundredths (86.52) feet to a point at the corner of Lot No. 13, as shown in the hereinafter mentioned plan of lots; thence along said Lot No. 13, North 22 degrees, 13 minutes West, two hundred fifty and thirty-nine one- hundredths (250.39) feet to a point; thence continuing along said Lot No. 13, North 18 degrees, 24 minutes West, one hundred sixty-two (162) feet to a point on the south side of McCormick Drive; thence along the south side of McCormick Drive, North 71 degrees, 36 minutes East, one hundred (100) feet to a point, the place of BEGINNING. BEING Lot No. 12 in the Plan of Section'C' of Lisburn Estates, as recorded in Plan Book 14, Page 38, in the Office of the Recorder of Deeds in and for Cumberland County. HAVING thereon erected a brick and aluminum split level dwelling known and numbered as l 1520 McCormick Drive. File #: 198815 BEING THE SAME PREMISES which John H. Kowalczyk and Kelly F. Kowalczyk, husband and wife, by Deed of even date, produced herewith and intending to be recorded, granted and conveyed unto Diane M. Ramp, a single woman, Mortgagor herein. SUBJECT to restrictions and conditions as contained in prior Deeds. PROPERTY BEING; 1520 MCCORMICK DRIVE PARCEL# 13-31-2136-078 File #: 198815 VERIFICATION I hereby state that I am the attorney for the 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 I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: 44/1110d &A % 2-DK 1% Attorney for P aini T I 419 File #: 198815 ( FEP ? E 2009 APR 13 AM i ! : 38 CLUE ti Ala . s o-pcLAl c kt::d w yzgs Sheriffs Office of Cumberland County R Thomas Kline 4?xtn aC cum6tr# Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE CF THE $HERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/18/2009 12:38 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 18, 2009 at 1238 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Diane M. Ramp, by making known unto Diane M. Ramp personally, at 1520 McCormick Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055, its contents and at the same time handing to her personally the said true and correct copy of the same. 04/18/2009 12:38 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 18, 2009 at 1238 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Brandlyn M. Ramp, by making known unto Diane M. Ramp, mother of defendant, at 1520 McCormick Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055, its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $57.50 April 21, 2009 SO ANSWERS, eooa'c:? ;r&, ? Docket No. 2009-2268 Us Bank National v Diane Ramp RLE?D-i; rRC E OF THE 2069A 27 11: 3 ob Phelan Halli an & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. H linan, Esq., Id. No. 62695 Daniel G. Sc ieg, Esq., Id. No. 62205 Michele M. radford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. S ah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. T as, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. S ivack, Esq., Id. No. 84439 Jaime McGu nness, Esq., Id. No. 90134 Chrisovalant P. Fliakos, Esq., Id. No. 94620 Joshua I. Go] an, Esq., Id. No. 205047 1617 JFK Bo levard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215_561-Inn US BANK N TIONAL ASSOCIATI ON, AS TRUSTEE FOR CITIGROU MORTGAGE LOAN TRUST 200 -WFHE4 Plaintiff VS. DIANE M. R?AMP BRANDL M. RAMP Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-2268 CIVIL TERM CUMBERLAND COUNTY PHS #: 1988 PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kind y substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for Plai tiff By: !L' Lawrence T. Phelan, Esquire ,,,Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Date: 05-15- 9 Joshua I. Goldman, Esquire PHS #: 1988 VERIFICATION Vice Preside US LO, and Corr that DATE: Yolanda Williams hereby states that he/she is )f Loan Documentation of WELLS FARGO BANK, N.A., servicing agent for Plaintiff, NK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE TRUST 2006-WFHE4, in this matter, that he/she is authorized to take this Verification, t the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and to the best of his/her knowledge, information and belief. The undersigned understands I statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom ltion to authorities. 4-14-09 of Loan Documentation Company: WELLS FARGO BANK, N.A. File #: 198615 Phelan Hall' an & Schmieg, LLP Lawrence T Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. S hmieg, Esq., Id. No. 62205 Michele M. radford, Esq., Id. No. 69849 Judith T. Ro ano, Esq., Id. No. 58745 Sheetal R. S ah-Jani, Esq., Id. No. 81760 Jenine R. D vey, Esq., Id. No. 87077 Lauren R. T as, Esq., Id. No. 93337 Vivek Sriv tava, Esq., Id. No. 202331 Jay B. Jones Esq., Id. No. 86657 Peter J. Mul ahy, Esq., Id. No. 61791 Andrew L. S ivack, Esq., Id. No. 84439 Jaime McG nness, Esq., Id. No. 90134 Chrisovalant P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 1617 JFK B ulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 I15-SFl-Inn US BANK ASSOCIA CITIGRO TRUST 20 ATIONAL ON, AS TRUSTEE FOR ' MORTGAGE LOAN -WFHE4 Plaintiff VS. DIANE M. BRANDLS M. RAMP Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-2268 CIVIL TERM CUMBERLAND COUNTY CERTIFICATE OF SERVICE I here y certify that a true and correct copy of Plaintifrs Praecipe to attach Verification of Complaint as sent via first class mail to the following on the date listed below: DIANE M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 BRANDLYN M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 Phelan Hallinan & Schmieg, LLP Attorney for Plain iff r By: /A&-- Lawrence T. Phelan, Esquire ,Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Fff~f?? -?-'m?v OF THE 'DTARY 1: t F ZQ h;-;Y Ell U i Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006- WFHE4 VS. DIANE M. RAMP BRANDLYN M. RAMP Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 09-2268 CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DIANE M. RAMP and BRANDLYN M. RAMP, Defendant(s) 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 Plaintiffs damages as follows: As set forth in Complaint $322,339.22 Interest - 04/09/2009 to 06/23/2009 $5,631.60 TOTAL $327,970.82 I hereby certify that (1) the Defendants' last known address is 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976, and (2) tha n tice has been given in accordance with Rule 237. 1, copy attached. f tawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jee ne R. Davey, Esquire ?Lauren R. Tabas, EsquiregO55--/ Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE/;HEREBY ASSESSED AS INDICATED. DATE: G7 PHS # 198815 PROTH NOTAR US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 Plaintiff V. DIANE M. RAMP BRANDLYN M. RAMP Defendant(s) TO: BRANDLYN M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 DATE OF NOTICE: June 2, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-2268 CIVIL TERM CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE 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 YOUR 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. PHS # 198815 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFEF AL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. ®® I ?' V^ Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 5e T/ Phelan, q., Id. No. 32227 S. allin sq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 4oshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 198815 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 Plaintiff V. COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-2268 CIVIL TERM CUMBERLAND COUNTY DIANE M. RAMP BRANDLYN M. RAMP Defendant(s) TO: DIANE M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 DATE OF NOTICE: June 2, 2009 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE 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 YOUR 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. PHS # 198815 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY ?1f ,ASLEF PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERV TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. ' Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 By: - /I 411?A La ce . he la', Esq., Id. No. 32227 Francis S. ' Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 /1'Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 198815 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006- WFHE4 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION VS. DIANE M. RAMP BRANDLYN M. RAMP : No. 09-2268 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney, hereby verifies that he/she is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DIANE M. RAMP is over 18 years of age and resides at 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055-5976. (c) that defendant BRANDLYN M. RAMP is over 18 years of age and resides at 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055-5976. This statement is made subject to the relating to unsworn falsification to authorities. of 18 Pa. C.S. Section 4904 Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Zatu me R.Davey, Esquire ren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff REDIT , E OF THE 2009 J UL Pry 3: 12 ??. piu- ao rte/ l'e ? Bi9y?? aa»ss ,?atiC? n (Rule of Civil Procedure No. 236) - Revised US BANK NATIONAL ASSOCIATION, CUMBERLAND COUNTY AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 COURT OF COMMON PLEAS VS. CIVIL DIVISION DIANE M. RAMP , BRANDLYN M. RAMP No. 09-2268 CIVIL TERM 1520 MCCORMICK DRIVE , MECHANICSBURG, PA 17055-5976 Notice is given that a Judgment in the above captioned matter has been entered against you on By: B -T71 1 1 If you have any questions concerning t is m tt r please cont t: Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenilte R. Davey, Esquire ?? (-L uren R. Tabas, Esquire933 Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PRE VIO USL Y RECEIVED A DISCHARGE IN BANKR UPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONL Y ENFORCEMENT OFA LIEN AGAINST PROPERTY. ** ~' US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 vs. DIANE M. RAMP BRANDLYN M. RAMP CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION N0.09-2268 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE The undersigned attorney hereby verify as follows: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached hereto Exhibit "A". DATE: ~ ~ By: Lawr T. Phelan Esq., Id. No. 32227 Fra cis S. Hallina ,Esq., Id. No. 62695 D iel . Sc 'eg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 ~hrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Attorneys for Plaintiff n. £OL613 6002 L o8L' 53N109 'a w O o U p.; ~.. v~ a ~ W a ~~ c~ o ~' ^d`~ ~ ~ U U ~ a; ~ ~~~ v~ -o ° a~ rn ~~a Uwe a ~~~ b a~ °a Rs s- a> v '~ a~i z+ "C7 ~ v ° „R °' ~- ~ ffi GL p CL U ' , ~ C dO T~ j O U G O ~ ~= E ~'N ~ °' ~ E ~ ~ v o cq E 'y s v 7 U ~ u E c v `n K '~ E ai W ~ ~ EG ~e+ O a ~ U ~C !-. 7 ~ ° "' n ;, -- U N ~ X G E W .g c v ,°~ 0 0 ~ V L 3 6 C ro y y ~ C U ~. O °~E~ E E ~ y ~ E °' ~ c m c ~, ?? ,~ ~ E ~ a E 'vu aoo diz woa~ a~i~w y ~ W 'x 0 "' ~ `~ ° flt~ O L08 1Zb000 J -~ a v ~H~ ~ - ~~ ( V ~+ , Wl ZO `N r, o E v~ o J U U A3Nlld Z Q e ~ ~ v ~ o ® ^ O cC ~ tAJd L d.~ ~ mc°'a'E ~ p ~ p i. M w °c° av° o w cff " -- o ~ '~ Cn a ~ ~ ooo;; ~o.. Eve ~~^ ~ s.: p > Q W ~ v .~ ~ `~ ~~ E ~ p O O E-~ a ~ $ '~ o g °' °` E..y ~ ch ~'' ~ ..-~ c~ o a W a - 3 .. s d ~ ~ o ~ a ~ ~ .~ H E" ~ a p ~ ~ p x -~"i -~i Q ~~ ~ ~~ ~ o ~ o z a `° .. oo ~-' a 'b ~O p ~ "~ cry w W ~ ;, v G j ~ W ~ o '~ a> > ~ c~d ~ ~~ V o y ~ a -~+ W ~ ~ ~ ~ ~ w w Q N ~ ( > 0 3 a~ r ~q ~ A a V a z ~ ~~~''M wa ° ~ t ~ ~ Q ~Aa ~~ a ~N 3 .~ ° . -i o°o Q' Q E-~~~ E-~ ~ ~ C7 ~ Q~p~ 3 Hw ¢ Qx~ . o a~ ~vNN, ~3 a N O Zz'~ O p; Z p: fY• ~ ~ z a O a ~ v~ ~ .~ p., ., W V z V" W W , W Z ~q ~ ~ ~~° a ~ az~~ ~ ~~~ ~ ~ ~Q r o~ w ~ ~~ a ~ ~ a ~• ~ ~ ~ U¢ ~~ ~OV a~~ a ia Goo 0. W ~ W ~ wo ~ a a ~; o ~ Q 1 i ~ W O C ~ ¢ z ~ ~ ~ ~ ~ o$ ~ ~a a~ ~l W A N ~ Z ° a U ~ o~ AU U UA U~o . a t~ ..-~ .~ ~1 Hx `m .a 3 z ~ d ~ b Q ~ A ~ °T ~~ ~a ~ ~--~ N M V' V'1 ~O t~ 00 O~ ~ ~-~ ~ Z ~ F !% ~ ^;nyr~~ L i.'j, J Yt `.. c 1 C_ e Llii~i~ ._. .. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson.. Sheriff Jody S Smith Chief Deputy ~~~ i ' .. [.rb _ f ,l_--- ~~ ~ ;r• _ ;~'r` Edward L Schorpp Solicitor ~'~'~t ' ':~ ^~ t ; UJ;U fig ~; ~ '~ ~~• r°,1~ L ~, C 1s i,J, ~; v _ 1. US Bank National Association Case Number vs. 2009-2268 Diane M. Ramp (et al.) SHERIFF'S RETURN OF SERVICE 10/02/2009 07:33 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 at 1933 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Diane M. Ramp &Brandlyn M. Ramp, located at 1520 McCormick Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. 10/02!2009 07:33 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 at 1933 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Diane M. Ramp, by making known unto, Brandlyn M. Ramp, adult in charge, at 1520 McCormick Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 10!02/2009 07:33 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 at 1933 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Brandlyn M. Ramp, by making known unto, Brandlyn M. Ramp, personally, at 1520 McCormick Drive, Mechanicsburg ,Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 12/07/2009 Property sale postponed to 2/3/2010. 01/29/2010 Property sale postponed to 4/7/2010. 04/06/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Schmieg on 416/10 SHERIFF COST: $714.30 SO ANSWERS, April 07, 2010 RON R ANDERSON, SHERIFF ~a.sa ?d S cry 7s2 rv 12~ .2 vas7o • US BANK NATIONAL ASSOCIATION, AS ~CRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 ' . Plaintiff, v. DIANE M. RAMP BRANDLYN M. RAMP CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION N0.09-2268-CIVIL-TERM Defendant(s). AFFH)AVIT PURSUANT TO RULE 3129.1 US BANK NATIONAL ASSOCIATION AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055-5976 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please indicate) DIANE M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 BRANDLYN M. RAMP 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) BUREAU OF COMPLIANCE DEPARTMENT 280946 HARRISBURG, PA 17128-0946 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who 1 Name LOWER ALLEN TOWNSHIP AUTHORITY LOWER ALLEN TOWNSHIP AUTHORITY C/O: STEVEN P. MINER, ESQUIRE ias any record lien on the property: Address (if address cannot be reasonably ascertained, please indicate) 120 LIMEKILN ROAD NEW CUMBERLAND, PA 17070 1035 MUMMA ROAD; SUITE 101 WORMLEYSBURG, PA 17043 6. Name end address of every other person who has any record interest in the property and whose interest may be a,£fected by the sale. Name None Address (if address cannot be reasonably ascertained, please indicate) 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 (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 6`h Floor, Strawberry Sq., Dept. 28061 Harrisburg, PA 17128 13`h Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 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.A. § 4904 relating to unsworn falsification to authorities. August 24, 2009 DATE ^ Law ce T. Phelan, Esq., Id. No. 32227 e ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ~Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215)563-7000 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 Plaintiff, v. DIANE M. RAMP BRANDLYN M. RAMP Defendant(s). CUMBERLAND COUNTY No.09-2268-CIVIL-TERM August 24, 2009 TO: DIANE M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 BRANDLYN M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 * *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 BANKR UPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055- 5976, is scheduled to be sold at the Sheriffs Sale on DECEMBER 9, 2009 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $327,970.82 obtained by US BANK NATIONAL ASSOCIATION AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 (215 563-7000. 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 (717) 240-6390. 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 of 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 the 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. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the south side of a fifty (50) foot street known as McCormick Drive, at the corner of Lot No. 11, as shown in the hereinafter mentioned plan of lots; thence along said Lot No. 11, South 18 degrees, 24 minutes East, three hundred eighty-eight and fifty-seven one-hundredths (388.57) feet to a point in the middle of the Yellow Breeches Creek; thence on a line in said Creek, South 56 degrees West, eighty-six and fifty-two one-hundredths (86.52) feet to a point at the corner of Lot No. 13, as shown in the hereinafter mentioned plan of lots; thence along said Lot No. 13, North 22 degrees, 13 minutes West, two hundred fifty and thirty-nine one-hundredths (250.39) feet to a point; thence continuing along said Lot No. 13, North 18 degrees, 24 minutes West, one hundred sixty-two (162) feet to a point on the south side of McCormick Drive; thence along the south side of McCormick Drive, North 71 degrees, 36 minutes East, one hundred (100) feet to a point, the place of BEGINNING. BEING Lot No. 12 in the Plan of Section 'C' of Lisburn Estates, as recorded in Plan Book 14, Page 38, in the Office of the Recorder of Deeds in and for Cumberland County. HAVING thereon erected a brick and aluminum split level dwelling known and numbered as 1520 McCormick Drive. TITLE TO SAID PREMISES IS VESTED IN Diane M. Ramp, a single person and Brandlyn M. Ramp, a single person, by Deed from Diane M. Ramp, a single person, dated 08/28/2007, recorded 09/05/2007 in Instrument Number 200734622. PREMISES BEING: 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055-5976 PARCEL NO. 13-31-2136-078 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-2268 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 Plaintiff (s) From DIANE M RAMP AND BRANDLYN M. RAMP (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$327,970.82 L.L.$.50 Interest from 6/24/2009-12/9/2009 (per diem - $53.91) $9,110.79 Atty's Comm % Due Prothy $2.00 Atty Paid $176.50 Plaintiff Paid Other Costs Date: August 25, 2009 (Seal) REQUESTING PARTY: Name Courtenay R. Dunn, Esq. Address: One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 Attorney for: Plaintiff Telephone: (215) 563-7000 Supreme Court ID No. 206779 / f ~ ~( Curtis R. Long,--Prat o of By: Deputy Real Estate Sale # On September 15, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 1520 McCormick Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 15, 2009 By: Rea EstatC~ e~oordmator ~,~-, ~~ ~,: -y~,~ ~~_ ~~ t?~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 23, October 30 and November 6, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Writ No. 2009-2268 Civll US Bank National Association, as Trustee for Citigroup Mortgage Loan Trust 2006-WFHE4 ~S. Diane M. Ramp Brandylyn M. Ramp Atty: Daniel Schmieg By virtue of a Writ of Execu- tion No. 09-2268-CIVIL-TERM, US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORT- GAGE LOAN TRUST 2006-WFHE4 vs. DIANE M. RAMP and BRANDLYN M. RAMP, owners of property situ- ate in LOWER ALLEN TOWNSHIP, Cumberland County, Peimsylvania, being 1520 McCORMICK DRIVE, ME- CHANICSBURG, PA 17055-5976. Parcel No. 13-31-2136-078. Improvements thereon: RESIDEN- TIAL DWELLING. .~- // lsa Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this 6 day of November, 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARL{SLE BORO, CUMBERLAND COUNTY My Commisston Expires Apr 28, 2010 The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c2~e ~lahiot News NoW you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Leslie Kramer, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/23/09 WrR No. X008-2168 CIv11 T'srm US Bank National Association, 10/30/09 as Trusbe for Citlgroup 11 /06/09 Mortgage Loan 7lrust 2006- Diane M. Remp Brandylyn. M. Rarrtp Atty: Daniel Schmleg By virtue of a writ of Execution Nq. 09-2z6s- .,. Sworn to a subscribed before me thi 6 d of " gvember, 2009 A.D. ctv>U~xtvt f ~, US BANK NATIONAL ASSOCIATION, AS .; ~~ TRUSTEE FOR CTTfGROUP MORTGAGE , . /'l~ o ~ ~ ~'" : lam : '~,. - IRAN , . __ , , _ . ; ~ __ - ~ --------~ TRUST2oo6-w~a , J" Notary Public vs. - DIANE M. RAMP and BRANDLYN M. RAMP Owner(s). of property situate io LOWER ALLEN TOWNSIIIP, Cumberland County, Peimsylvania, being (Municipality) 1520 MCCORMICK DRIVE, MECHANICSBURG PA 70 5976 l P COAAMONWEAL , arce 1 55- . ~pF PENNSYLVANIA No.13-31-2136.078 Notarial S~ah'~ Ln rovemen trcet ~eredn: RESIDENTIAL P CS~~ ~ lCisner' Mary Public dY Of Harrisburr~ Da DQJP,LLING , uphin Courtly My Commission Expire P s 1ou. 26, 2011 Member, Penns l y vania Assoriafion o£ Notaries AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF ASSOCIATION, AS TRUSTEE FOR US BANK NATIONAL pHs # 198815 CiTIGROUP MORTGAGE LOAN TRUST 2006-WFHFA SF?VI('.E'IZi.AM/ 11ZC DEFENDANT COURT NO.: 09-2268 CIVIL TERM DIANE M. RAMP BRANDLYN M. RAMP TYPE OF ACTION SERVE DIANE M RAMP AT: XX Notlee of Sberifrs Sale 1520 MCCORMICK DRIVE SALE DATE: 03/0212011 MECHANICSBURG, PA 17055-5976 MVED Defendant on the q4 day of Naves • DIANE M. RAIvI?? Served and made known to 20 /O , at P Defendant ?. M., at i??Rht ?? Pao Y?' in the manner described below: P0fendant personally served. M ?A A? _ Adult family member with "Whom Defendant(s) reside(s). Relationship is Adult m charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of of lodging ?in which t office f or usual placer of business. _ Agent or person in charg an officer of said Defendant's company r w S F Other ? na "rl rnco =M X= rrl C-S mr' t- -<> M r C}o M 3 ? ._ Ul ? S ? r 4, p Race ex Description: Age I AD- Height _tL - Weight ?„?Jp t /VIAI.t- , a competent adult, being duly sworn according to law, depose and state that I personally L Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned handed a true and correct COPY of the case on the date and at the address indicated above. yjMBERLY CURV sworn to and sub ri bed C NOT?YjERSEY before me this 'r7h ?Y ` ?1? ?? MARCH 1, 2013 Of C N By' NOTE 20_, at _ o clock _• M•, Defendant NOT FOUND because: On the Y - Moved - Does Not Reside (Not Vacant) Does Not Exist - at No Answer on -at--- service - r Service Refused Other: Sworn to and subscribed before me this day of Notary: By. An9R!9 FORPI.AINTf (warm T. ftd-,S0+ li Na 33227 ¦erd0 s. Nir4 v4.- Nw 6788 Drill G. Sasie604+, Y• N0.637L5 ,,&& 00. B.Wb,,i, SO„ td. Nw am J.M& T. DOS00. KN611L Na WM qMW IL y?,Jri, Sq, 1a. Nw 017N Jaye R Dne7, g%„ rd.Na 070r/ L.. .0.TdA%r,4,t?N-707331 Vbdc8dad0o,S%.a. Jq&Jar0, S0, I& &W60 t 141sT J. HWft. rb0+ Al-I S. 80NOd47b9-M•Ns. Nd" JdM MCGiae. Sala. Ns.90136 G MWAft WA-6 K "& 2WW prt.q R D WA, OLy.ld. Ne.786TA Atl[a„G 9,O?Oyll, J&No2M375 sbon 1400 8 1Q7 r? p06.depmO PAM011014 OM 563-70M L AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAY IIFF US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFAE4 DEFENDANT DIANE M. RAMP BRANDLYN M. RAMP SERVE BRANDLYN M. RAMP AT: 1520 MCCORMICK DRIVE MECAANICSBURG, PA 17055-5976 PAS # 190815 SER) M TEAM/ lac COURT NO.: 09-2268 CIVIL TERM TYPE OF ACTION XX Notice of SheriR's Sale SALE DATE: 03/0=11 t°-a C -? 3 rn ca ?'Ct Ln ? .r >C-) C? e? c? C? rn C-) I tr 3 3 to W --i SERVED (j? Served and made known to RAND IN M. P Defendant on the 411 day of N#VeMW, 20 L, at 1i, 00 , o'clock g. M., at f ??oRMt GC 1?R? V E in the manner described below: Defendant personally served. MF A*Qtes bif", pA , Adult family member with whom Defendant(s) reside(s)- Relationship is Mmysg _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person W charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. _ Other: rE Description: Age te- Height ? Weight 12 v _ Race w Sex F Other 1 KnAe&I> A& & (, L _, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Nark of Sheriffs Sale in the manner as set forth herein, issued in the captioned --i ? ^rl C) C?'11 Ca ? --G case on the date and at the address indicated above. Sworn to and su r-bed KIMBERLY CURY before me this day NOTARY BM IC of o , 20,U. I STATE OF NY C/?/V MY CQMMISSION EXPMARCH 7,..3 N Y* NOT S On , 20^, at _ & clock _. M., Defendant NOT FOUND because: ant _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of 7 2(F_ - By: Notary: ATTORNEY FORM ALVI7FF LMw,ree T. nNIM 61I., IL Ne. 32227 F.Mb S )Yi04 ft. I& Na OW ===n= is"T. Reese, Fiq. K Nw 9745 9WWLNW JW.Sy.bLN?81768 j=j=L Drm, r,+, LL Ne. 87877 Liro L bhn, 6a0„ 81. Nw"M Vbiaseinewo 64.ALNw28W1 joy L rw., Pay, 6L Ns SW Peler2.848dy, Fay, LNw61791 Andrew Lead,, rieq, bL Nw 81179 Jai?sM,Gdrs, Fay, Y. N& 90134 (%-bog alFe1 P.F8eb14Fa1j.1d.Na91620 ]air L Geld,, Ely, Id. NL 20917 Canler R. Do, ftll, bt Ne. 2*779 AnewG91Wbld1. bLNw21&715 Ig7]?be W - PA V PA lIN PbBtl,y,, 191831814 (215)563-7M WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-2268 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U S BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4, Plaintiff (s) From DIANE M. RAMP AND BRANDLYN M. RAMP (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: $341,127.71 L.L.: Interest FROM 12/10/2009 TO DATE OF SALE ($56.08 PER DIEM) - $45,929.52 Atty's Comm: % Atty Paid: $925.80 Plaintiff Paid: Due Prothy: $2.00 Other Costs: Date: DECEMBER 1, 2011 (Seal) David D. Buell, P othonotary By: Deputy REQUESTING PARTY: Name: ALLISON F. WELLS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 309519 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP COURT OF COMMON PLEAS MORTGAGE LOAN TRUST 2006-WFHE4 Plaintiff CIVIL DIVISION V. DIANE M. RAMP BRANDLYN M. RAMP Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 12/10/2009 to Date of Sale ($56.08 per diem) TOTAL Note: Please attach description of property. PHS # 198815 5?. 5v -COS+B /?"7• ?V - it r ga. lAf. 60 ,, rr --X1.GU 2S. $G- NO.: 09-2268 CIVIL TERM CUMBERLAND COUNTY $341,127.71 $45,929.52 Attorney for Plaintiff ?119 Z_' P_4? a?749e :;--M < M° 3 ;r -? r? L'> 0 a F' ? ? rn ? o W ? ? x0 O Ot) U C? 0 w H o d oa ? w W? w ao BOO ? ? ? rA „a H? ?? AA a Z, U PHELAN HALLINAN & SCHMIEG, LLP Attorneys for Plaintiff Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR COURT OF COMMON PLEAS CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 Plaintiff CIVIL DIVISION V. NO.: 09-2268 CIVIL TERM DIANE M. RAMP CUMBERLAND COUNTY BRANDLYN M. RAMP Defendant(s) CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relat' falsification to authorities. PI an & Schmieg, LEE Allison F. Wells, Esq., Id. No.309519 Attorney for Plaintiff er f ry co C-.) -OrT , ?C3 Q C-, = C:D c rv r,. <:) j US BANK NATIONAL ASSOCIATION, AS TRUSTEE COURT OF COMMON PLEAS FOR CITIGROUP MORTGAGE LOAN TRUST 2006- WFHE4 CIVIL DIVISION Plaintiff NO.: 09-2268 CIVIL TERM V. CUMBERLAND COUNTY DIANE M. RAMP BRANDLYN M. RAMP PHS # 198815 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006- WFHE4, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055- 5976. Name and address of Owner(s) or reputed Owner(s) 2 3 4 5 Name Address (if address cannot be reasonably ascertained, please so indicate) :. Zc DIANE M. RAMP 1520 MCCORMICK DRIVE Z ? t=- MECHANICSBURG, PA 17055-5976 CD C5 I BRANDLYN M. RAMP 1520 MCCORMICK DRIVE r - 'S -p •--t c) { --n MECHANICSBURG, PA 17055-5976 c Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) BUREAU OF COMPLIANCE BUREAU OF COMPLIANCE DEPARTMENT 280946 HARRISBURG, PA 17128-0946 DEPARTMENT 280948 HARRISBURG, PA 17128-0946 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) LOWER ALLEN TOWNSHIP AUTHORITY 120 LIMEKILN ROAD NEW CUMBERLAND, PA 17070-2428 LOWER ALLEN TOWNSHIP AUTHORITY 635 NORTH 12TH STREET C/O STEVEN P. MINER, ESQUIRE SUITE 101 LEMOYNE, PA 17043-1225 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 None. Address (if address cannot be reasonably ascertained, please indicate) 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 (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 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 of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: 1 Allison F-WrR, Esq., Id. No.3 Attorney for Plaintiff ties US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR COURT OF COMMON PLEAS CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 CIVIL DIVISION Plaintiff • NO.: 09-2268 CIVIL TERM VS. i-) na CUMBERLAN..?OiT-Y, cxa c? ?-Y; DIANE M. RAMP, BRANDLYN M. RAMP'` r ? Defendant(s) ?ir.a sue; C -NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BRANDLYN M. RAMP DIANE M. RAMP 1520 MCCORMICK DRIVE 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 MECHANICSBURG, PA 17055-5976 "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, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055-5976 is scheduled to be sold at the Sheriff's Sale on 03/07/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $341,127.71 obtained by US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006- WFHE4 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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 canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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 Sheriffs Sale is not stopped. your property Will be sold to the hlJlest bidder. You may find out the price bid by calling 215-563-7000. 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 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 the filing of the proposed schedule. 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. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the south side of a fifty (50) foot street known as McCormick Drive, at the corner of Lot No. 11, as shown in the hereinafter mentioned plan of lots; thence along said Lot No. 11, South 18 degrees, 24 minutes East, three hundred eighty-eight and fifty-seven one-hundredths (388.57) feet to a point in the middle of the Yellow Breeches Creek; thence on a line in said Creek, South 56 degrees West, eighty- six and fifty-two one-hundredths (86.52) feet to a point at the corner of Lot No. 13, as shown in the hereinafter mentioned plan of lots; thence along said Lot No. 13, North 22 degrees, 13 minutes West, two hundred fifty and thirty-nine one-hundredths (250.39) feet to a point; thence continuing along said Lot No. 13, North 18 degrees, 24 minutes West, one hundred sixty-two (162) feet to a point on the south side of McCormick Drive; thence along the south side of McCormick Drive, North 71 degrees, 36 minutes East, one hundred (100) feet to a point, the place of BEGINNING. BEING Lot No. 12 in the Plan of Section 'C' of Lisburn Estates, as recorded in Plan Book 14, Page 38, in the Office of the Recorder of Deeds in and for Cumberland County. LAVING thereon erected a brick and aluminum split level dwelling known and numbered as 1520 McCormick Drive. SUBJECT to restrictions and conditions as contained in prior Deeds. TITLE TO SAID PREMISES VESTED IN Diane M. Ramp, a single person and Brandlyn M. Ramp, a single person, by Deed from Diane M. Ramp, a single person, dated 08/28/2007, recorded 09./05/2007 in Instrument Number 200734622. PARCEL NO. 13-31-2136-078. SHORT DESCRIPTION By virtue of a Writ of Execution NO. 09-2268 CIVIL TERM US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 vs. DIANE M. RAMP BRANDLYN M. RAMP owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055-5976 Parcel No. 13-31-2136-078. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $341,127.71 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 PHS # 198815 DEFENDANT DIANE M. RAMP BRANDLYN M. RAMP SERVE BRANDLYN M. RAMP AT: 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 SERVICE TEAM/ Igh COURT NO.: 09-2268 CIVIL TERM TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: March 7, 2012 SERVED ) Served and made known to BRANDLYN M RAMP Defendant on the 4 da f b 20 " . , y o f? , o'clock f. M., at 1520 u l,G &-Q#4 W- tk , in the manner described below: , at Defendant personally served. G Adult family member with whom Defendant(s) reside(s). Relationship is (M&- Adult in charge of Defendant's residence who refused to give name or relationship. =:?o c') r - Manager/Clerk of place of lodging in which Defendant(s) reside(s). N tJy - Agent or person in charge of Defendant's office or usual place of business. ' rr -Z _ an officer of said Defendant s company. _ Other: Description: Age :5-,a- Height f ° Weight Race W Sex Other ?`1-Z• •• ???? '' '' 1, ?L1b 't-a't4N , a competent adult, hereby verify that I personally handed a true and correct 6$y of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date an d at the address indicated above. I understand that this statement is made subject to the penaltie 8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: (2.t.'- t I NAME. PRINTED NAME: TITLE: t 120 cg!?r5 NOT SERVED On the day of , 20-, at - o'clock _. M., Defendant NOT FOUND because: - Vacant - Does Not Exist ` Moved - Does Not Reside (Not Vacant) _ No Answer on at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Hiakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Gl "t7 C.? S ~? 5-n 4 PLAINTIFF US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 DEFENDANT DIANE M. RAMP BRANDLYN M. RAMP SERVE DIANE M. RAMP AT: 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 PHS # 198815 SERVICE TEAM/ lxh COURT NO.: 09-2268 CIVIL TERM TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: March 7, 2012 SERVED Served and made known to DIANE M. RAMP, Defendant on the day of D9-e- 20 ?f at o'clock g. M., at (°SZC? lMc Cc?1wuC4 in the manner described below: efendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship is - Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). - Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: n r?> 2r n ?? GV z p0 Zt? Description: Age ? Height !5 1Or Weight l Race W Sex Other a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. c r 1 DATE: 12 _6--1 1 N PRINTED NAME: TITLE: f &eess selzui I NOT SERVED On the day of , 20,, at _ o'clock _. M., Defendant NOT FOUND because: - Vacant - Does Not Exist _ Moved - Does Not Reside (Not Vacant) - No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetai R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 AFFIDAVIT OF SERVICE CUMBERLAND COUNTY ?t ? -r tr? ?.. 'L3 rn =p C:1 t s-Y'1 Q C"3 - J". -C PHELAN HALLMAN & SCHMIEG, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 f'E?vl U Attorney for Plaintiff :' ' ?FEUD 2? AN 9: 11 ;iJ `!3ERLAN,D C0UjNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA US BANK NATIONAL ASSOCIATION, AS CUMBERLAND COUNTY TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 COURT OF COMMON PLEAS Plaintiff, V. DIANE M. RAMP BRANDLYN M. RAMP Defendant(s) CIVIL DIVISION No.: 09-2268 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth Affidavit and as amended if applicable. A copy of the Certificate of Mailing (For 3817) an or Certified Mail Return Receipt stamped by the U.S. Postal Service is attaWbert, bit "A". quire Date: IM PORTANT N TICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS 4 198815 EXHIBIT "A" 1 j f ? f 0.? r ?I ..., j N' F l t ;n Y O ?? ? N) r, '* my ?Iv<pO ,, ?? J CID ? i w + I I W 1 $ ? t r C ' ? I ? ? ."J Qy ire+I ti t, N-Y u ? O V GC ,7 a . y U n. H ?? .1i H O O ww O T +? ell I W Q ?n O 0.r ?Sx° ' LxA c a ,. . O'n t5 E ET's cc i, LQ a q?rrr W;. ? l C46 a awv? -I G?V v( Vp0. .C i { y 0 T ? H C C?1 pp w F C C N c v 2 ^ F o L _ b0 F i, ? o ? z x: n C n j ' c v _E d X C A u) E 'u U ? ? y U ? C C C L ff. C O O t3 OP ? w? o j C w I ? p C E i r F r o ? L F f _ ? v X G • r F ? 0 k u a Ea n eo E u°. C c ?y C v 'z v °a J J. T 4 N W d ? a d ? G 1 ? ? 7 r+ as ? .. ? ?ycn a° ?« ?drW•?o" C. ca x w?? d d M? 3 0 M o 0 V raj G 4 w < '+? b Q C ?3 0 ?•? V r ?rl w tL ??? C q 4 Iyt ? ? ? " N V M li W S N d?. ? t <c, rM w i b b v? D 3 US BANK NATIONAL ASSOCIATION, AS TRUSTEE COURT OF COMMON PLEAS FOR CITIGROUP MORTGAGE LOAN TRUST 2006- WFHE4 CIVIL DIVISION Plaintiff NO.: 09-2268 CIVIL TERM V. CUMBERLAND COUNTY DIANE M. RAMP BRANDLYN M. RAMP PHS # 198815 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006- WFHE4, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055- 5976. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) DIANE M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 BRANDLYN M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) BUREAU OF COMPLIANCE DEPARTMENT 280946 HARRISBURG, PA 17128-0946 BUREAU OF COMPLIANCE DEPARTMENT 280948 HARRISBURG, PA 17128-0946 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) LOWER ALLEN TOWNSHIP AUTHORITY 120 LIMEKILN ROAD NEW CUMBERLAND, PA 17070-2428 Lower Allen Township 2233 Gettysburg Road Camp Hill, PA 17011 LOWER ALLEN TOWNSHIP AUTHORITY C/O STEVEN P. MINER, ESQUIRE Lower Allen Township Authority C/O Daley Zucker Meilton Miner & Gingrich, LLC Attn: Steven P. Miner, Esquire 635 NORTH 12TH STREET SUITE 101 LEMOYNE, PA 17043-1225 1035 Mumma Road, Suite 101 Wormleysburg, PA 17043 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 (if address cannot be reasonably ascertained, please indicate) None. 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 (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 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 11 re made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to autho ' 'es. Date: (/ ?v By: Phe n Hal n & Schmieg, LLP Robert W. Cusick, Esq., Id. No.80193 Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor t `Pf OTHONOTA t 2212 JUN 27 AM 8: 46 "UMBEftAND COUNTy PENNSYLVANIA US Bank Trust National Association vs. Case Number Diane M. Ramp (et al.) 2009-2268 SHERIFF'S RETURN OF SERVICE 01/05/2012 06:12 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1520 McCormick Drive, Mechanicsburg, Cumberland County, PA 17055. 01/10/2012 06:13 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Brandlyn M. Ramp at 1520 McCormick Drive, Lower Allen Township, Mechanicsburg, PA 17055, Cumberland County. 01/10/2012 06:13 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be BRANDLYN RAMP-DAUGHTER, who accepted as "Adult Person in Charge" for Diane M. Ramp at 1520 McCormick Drive, Lower Allen Township, Mechanicsburg, PA 17055, Cumberland County. 02/29/2012 As directed by Daniel G Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/2/2012 04/26/2012 As directed by Daniel G Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/11/2012 06/25/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $724.90 SO ANSWERS, June 25, 2012 RONK?l R ANDERSON, SHERIFF -7 ?_2 a• v US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGWOUP MORTGAGE LOAN TRUST 2006- WFHE4 Plaintiff V. DIANE M. RAMP BRANDLYN M. RAMP Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 09-2268 CIVIL TERM CUMBERLAND COUNTY PHS # 19881.5 AFFIDAVIT PURSUANT TO RULE 3129.1 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006- WFHE4, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055- 5976. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) DIANE M. RAMP BRANDLYN M. RAMP 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) BUREAU OF COMPLIANCE DEPARTMENT 280946 HARRISBURG, PA 17128-0946 BUREAU OF COMPLIANCE DEPARTMENT 280948 HARRISBURG, PA 17128-0946 4. Nam.e wi address vl rCCvrua.u LVILLI.I Vl a.vWy 111Vl lgQb'G 011Gl.V1 U. Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot he rci,ionablr ascertainrd_ E?Ir,isr indicate) LOWER ALLEN TOWNSHIP AUTHORITY 120 LIMEKILN ROAD NEW CUMBERLAND, PA 17070-2428 LOWER ALLEN TOWNSHIP AUTHORITY 635 NORTH 12TH STREET C/O STEVEN P. MINER, ESQUIRE SUITE 101 LEMOYNE, PA 17043-1225 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 (if address cannot be reasonably ascertained, please indicate) None. 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 (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 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 of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: By: Allison-F-WtH, Esq., Id. No.309 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 Plaintiff DIANE M. RAMP BRANDLYN M. RAMP VS. Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 09-2268 CIVIL TERM CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BRANDLYN M. RAMP DIANE M. RAMP 1520 MCCORMICK DRIVE 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 MECHANICSBURG, PA 17055-5976 "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, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 1520 MCCORMICK DRIVE, MECHANICSBURG, PA 17055-5976 is scheduled to be sold at the Sheriff's Sale on 03/07/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $341,127.71 obtained by US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006- WFHE4 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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 canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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 attorne_y.) 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 [I1c shcrif?-, ]? not sl0?1)hcd. vour hr??hcr(? ?? ill he >??I?i tO the hi?'hc'i hlddcr. l ??u llm-v iin(l Oul the price bid by calling 2I5-563-7000. r 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 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 the filing of the proposed schedule. 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. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the south side of a fifty (50) foot street known as McCormick Drive, at the corner of Lot No. 11, as shown in the hereinafter mentioned plan of lots; thence along said Lot No. 11, South 18 degrees, 24 minutes East, three hundred eighty-eight and fifty-seven one-hundredths (388.57) feet to a point in the middle of the Yellow Breeches Creek; thence on a line in said Creek, South 56 degrees West, eighty- six and fifty-two one-hundredths (86.52) feet to a point at the corner of Lot No. 13, as shown in the hereinafter mentioned plan of lots; thence along said Lot No. 13, North 22 degrees, 13 minutes West, two hundred fifty and thirty-nine one-hundredths (250.39) feet to a point; thence continuing along said Lot No. 13, North 18 degrees, 24 minutes West, one hundred sixty-two (162) feet to a point on the south side of McCormick Drive; thence along the south side of McCormack Drive, North 71 degrees, 36 minutes East, one hundred (100) feet to a point, the place of BEGINNING. BEING Lot No. 12 in the Plan of Section 'C' of Lisburn Estates, as recorded in Plan Book 14, Page 38, in the Office of the Recorder of Deeds in and for Cumberland County. HAVING thereon erected a brick and aluminum split level dwelling known and numbered as 1520 McCormick Drive. SUBJECT to restrictions and conditions as contained in prior Deeds. TITLE TO SAID PREMISES VESTED IN Diane M. Ramp, a single person and Brandlyn M. Ramp, a single person, by Deed from Diane M. Ramp, a single person, dated 08/28/2007, recorded 09/05/2007 in Instrument Number 200734622. PARCEL NO. 13-31-2130078. SHORT DESCRIPTION By virtue of a Writ of Execution NO. 09-2268 CIVIL TERM US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 vs. DIANE M. RAMP BRANDLYN M. RAMP owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 1520 MCCORMICK DRIVE MECHANICSBURG PA 17055-5976 Parcel No. 13-31-2136-078. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $341,127.71 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) L.L.: TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U S BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4, Plaintiff (s) From DIANE M. RAMP AND BRANDLYN M. RAMP (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: $341,127.71 Interest FROM 12/10/2009 TO DATE OF SALE ($56.08 PER DIEM) - $45,929.52 Atty's Comm: % Any Paid: $925.80 Plaintiff Paid: Date: DECEMBER 1, 2011 (Seal) Due Prothy: $2.00 Other Costs: J David D. Buell, Prothonotary By: NO 09-2268 Civil CIVIL ACTION - LAW REQUESTING PARTY: Name: ALLISON F. WELLS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attornev for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 309519 Deputy TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said COL at Carlisle, Pa. This day of 21) 1_ -4:nt K1 Prothonotary r On December 19, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as, 1520 McCormick Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date December 19, 2011 By: &Lau? II&"akL) Real Estate Coordinator L 1 .1 ? % - TiG H oz CUMBERLAND LAW JOURNAL Writ No. 2009-2268 Civil Term US Bank National Association, As Trustee for Citigroup Mortgage Loan Trust 2006-WFHE4 vs. Diane M. Ramp and Brandlyn M. Ramp Atty.: Daniel Schmieg By virtue of a Writ of Execu- tion NO. 09-2268 CIVIL TERM, US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CI71GROUP MORT- GAGE LOAN TRUST 2006-WFHE4 vs. DIANE M. RAMP, BRANDLYN M. RAMP owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being 1520 McCORMICK DRIVE, MECHANICSBURG, PA 17055-5976. Parcel No. 13-31-2136-078. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $341,- 127.71. 64 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 27, February 3, and February 10, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. before me this 0 da of Febru 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 2B, 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA, 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 14f patriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01/27/12 02/03/12 t 02/10/12 \ a ........ ... tk Sworn to an bscribed befo his of ebruary, 2012 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA i Notarial seal Sherrie L. Owens, Notary Public Lower Paxton Two., Dauphin County My CDMMMSlon Nov. 26 2015 MEMBER, PENNSYLVAWTAAWWTJ ?S The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE i4fPatr1*0t0&XfW5 Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Apt No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn accord ng to !aw.. deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its prircipal office and place of business at 2020 Technology Pkwy, Suite 300. in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid, that The Patriot-News and The Sunday Patriot-News were established March 4th. 1854, and September 18th. 1949 respectively, and all have been continuously published ever since; That the printed notice or publication whict is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statemenr as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement cn behalf of The Patriot-News Co. atoresaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscella-ieous Book "M" Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01/27/12 2009.2268 Civil Term S Bank National Association, as Trustee for CRlgroup Mortgage Loan Trust 2006- WFHE4 VS Diane M. Ramp and Brandlyn M. Ramp Atty. Daniel Schmleg By virtue of a Writ of Execution NO. 09- 2268 CIVIL TERM US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR crnGROUP MORTGAGE IRAN TRUST 2006- WFHE4 vs. DIANE M. RAMP BRtNDLYN M. RAMP owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 1526M000RMICK DRIVE, MECHANICSBURG, PA 17055-5976 Dares l No. 13-31-2136-078. (A ge or street address) rmnrrnramenfc thereon: RESIDENTIAI. 02/03/12 02/10/12 Swo-n to and subscribed before me'this 24 day of February, 2012 A.D. Notary Public -OMMONWIEALTH OF PENNSYLVANIA Notarial Seal 4 Sherrie L. Owens, Notary Public LoWer Paxton Twp., Dauphin County my Commission EVres Nov. 26, 2015 MFMrt- PENNSYLVANIA A65MI ON OF NOTARIES k Phelan Hatlinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 1Nt PROT'HONOTAR'i' 2012 JILL 2 6 AM 11; Mtorney For Plaintiff CUMBERLAND COUNTY PENNSYLVANIA US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 Plaintiff vs DIANE M. RAMP BRANDLYN M. RAMP Defendant TO THE PROTHONOTARY: Court of Common Pleas Civil Division CUMBERLAND County No. 09-2268 CIVIL TERM PRAECIPE ? Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ? Please mark the above referenced case Settled, Discontinued and Ended. ® Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ? Please mark the in rem judgment Satisfied and the action Discontinued and Ended. 7/--/' 2 PHELA ?N & SCHMIEG, LLP Date: By* Jo ichael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff PHS # 198815 Qw'k C). So Pd of Ck, µl9O47o"S V4 2 7gy-t 1 b Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 Plaintiff Attorney For Plaintiff Court of Common Pleas Civil Division CUMBERLAND County vs DIANE M. RAMP BRANDLYN M. RAMP Defendant No. 09-2268 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: DIANE M. RAMP BRANDLYN M. RAMP 1520 MCCORMICK DRIVE MECHANICSBURG, PA 17055-5976 Date: /2 C By: John ichael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff PHS # 198815