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HomeMy WebLinkAbout09-4377fl Leon P. Haller, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717.234.4178 mtg@pkh.com U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY vs. Plaintiff CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 the 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 claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff vs. CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff vs. CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust Indenture dated as of April 1, 1982 ("Trust"), is a National Association with a Servicing Agent of the Pennsylvania Housing Finance Agency, with an address of 211 North Front Street, Harrisburg, Pennsylvania 17101. 2. Defendants, CHASITY J. RAMIREZ and ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, are adult individuals whose last known address is 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011. 3. On or about, February 26, 2007, the said Defendants executed and delivered a Mortgage Note in the sum of $163,706.00 payable to NATIONAL CITY MORTGAGE a division of NATIONAL CITY BANK, which Note is attached hereto and marked Exhibit "A" 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth on March 1, 2007 in Mortgage Book 1983, Page 4149 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to PENNSYLVANIA HOUSING FINANCE AGENCY and was recorded in the aforesaid County on May 18, 2007 in Mortgage Book 737, Page 100. The Mortgage was further assigned to U.S. BANK, NATIONAL ASSOCIATION, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording. The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on October 01, 2008 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $159,076.00 Interest at $23.20 per day $7,029.60 From 09/01/2008 To 07/01/2009 ( based on contract rate of 5.2500%) Accumulated Late Charges $463.24 Late Charges $36.16 $325.44 From 10/01/2008 to 07/01/2009 Escrow Deficit $1,128.67 Attorney's Fee at 5% of Principal Balance $7,953.80 TOTAL $175,976.75 "Together with interest at the per diem rate noted above after July 01, 2009 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendants by letters dated April 14, 2009 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the April 14, 2009 Act 6 Notice is attached hereto and marked Exhibit "C". 10. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 11. The Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 5.2500% ($23.20 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By: ' ' 4?? P CELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) Multistate NOTE =44179117*219- 703 February 26, 2007 0005351531 [Date] 119 S LOCUST ST, SHIREMANSTOWN, Pennsylvania 17011 l / [Property Address] T/ ° J 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means National City Mortgage a division of National City Bank and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of ONE HUNDRED SIXTY THREE THOUSAND SEVEN HUNDRED SIX & 00/100 Dollars (U.S. $ 16 3 , 7 0 6 . o o plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of FIVE AND ONE-QUARTER percent( 5-250 %) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on April 1 2007 . Any principal and interest remaining on the first day of March 2037 , will be due on that date, which is called the "Maturity Date." ' (B) Place Payment shall be made at National City Mortgage Co. PO Box 533510 Atlanta, GA 30353-3510 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 904.00 will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest tanoamount ther items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ?Graduated Payment Allonge ?Growing Equity Allonge ?Other [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. -1 R (0210) pHA Multistate Fixed Rate Note - 10/95 ® VMP Mortgage Solutions (800)521-7291-/ Page 1 of 2 Initials Alod ?V-- I IIIIIII VIII II IIIIIIIIIilllllll III 0 1 rl ?, 9 ` kA 00\ ??1 ?' E 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent( 4.00 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. (Seal) au ISRAEL M RAMIREZ Borrower CHASITY J Ey (Seal) -Borrower - (Seal) (S?) -Borrower PAY TO THE ORDER OF PENNSYLVANIA Borrower HOUSING FINANCE AGENCY WITHOUT _ (Seal) RECOURSE BY NATIONAL CITY MORTGAGE Borrower (Sa) Borrower - (S , .o (Seal) -Borrower EVANS • l1iORTGAGE OFFICER XKKKKK = -1 R (0210).01 ® Page 2 of 2 ALL THAT CERTAIN house and lot of ground situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of South Locust Street, said point being 425.60 feet southeast of the Southeast corner of Locust Street and Parish Alley; thence along the line of a ten (10) foot wide private drive, North 70 degrees, 56 minutes, 10 seconds East, 124.62 feet to a point; thence along the line of Lot No. 2B as shown on the hereinafter mentioned Plan of Lots, South 19 degrees, 03 minutes, 50 seconds East, 76.61 feet to a point; thence along the line of Lot No_ I on said Plan, South 65 degrees, 07 minutes, 00 seconds West, 108.29 feet to a point on the East side of South Locust Street, aforesaid; thence along said side of South Locust Street, North 29 degrees, 58 minutes, 00 seconds West, 89.19 feet to a point, the place of BEGINNING. BEING Lot No. 2A on the final subdivision plan of Herbert Benner, which said Plan is recorded in the Cumberland County Recorder's office in Plan Book No. 24, at page 20. BEING known and numbered as 119 South Locust Street, Shiremanstown, Pennsylvania. Pennsylvania Housing Finance Agency Accounting / Loan Servicing Division 211 North Front Street, P.O. Box 15057 Harrisburg, PA 17105-5057 (1-800-822-7375) 07 -(717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 CERTIFIED MAIL - RETURN RECEIPT REQUESTED April 14, 2009 RE: Account No 1527761 ISRAEL M RAMIREZ CHASITY J RAMIREZ 119 S LOCUST ST SHIREMANSTOWN, PA 17011-6733 RE: 119 S LOCUST ST SHIREMANSTOWN, PA 17011-6733 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter we, us or ours) on your property located at 119 S LOCUST ST, SHIREMANSTOWN, PA 1 701 1-6733 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,194.00 for October 1, 2008 through April 1, 2009 for a total of $8,358.00. Late charges and NSF charges that have accrued to this date in the amounts of $390.92 and $0.00 respectively, are also due. The total listed below includes all fees (including inspections and securing that needed to be completed) less any funds we are holding in suspense. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $8,782.92. You may cure this default within thirty (30) DAYS of the date of this letter, by paying to us the total amount of $8,782.92, plus any additional monthly payments, expenses and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order and made at: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET/P.O. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 or TTY (800) 346-3597 If you do not cure the default within THIRTY (30) DAYS, We intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortga eed property. If the mortgage is foreclosed, your mortgage property will be sold by the sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to ? 1? 1 i Pennsylvania Housing Finance Agency Accounting / Loan Servicing Division 211 North Front Street, P.O. Box 15057 Harrisburg, PA 17105-5057 (1-800-822-7375) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees, even if they are over $50.00. Any attorney's fee will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the sheriff's foreclosure sale. You may do so by paving the total amount of the unpaid monthly payments and any late or other charges then due as well as the reasonable attorney's fees and const connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately five months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-800-822-7375. This payment must be made payable in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL "THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. You have the right to assert in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents, the nonexistence of a default or any other defense you believe you may have to any such action. If you maintain credit, life or disability insurance in connection with your mortgage loan, your failure to pay premiums with your payments may have already resulted or may result in the future in the lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply to the insurance company and qualify for replacement insurance if you wish to retain it. If you make partial payments on account of the delinquencies, we may accept them and apply them to the delinquencies. However, such partial payments will not cure your default or reinstate your loan. The loan will not be reinstated unless we receive the entire amount required to cure the default. Pennsylvania Housing Finance Agency Accounting / Loan Servicing Division 211 North Front Street, P.O. Box 15057 Harrisburg, PA 17105-5057 (1-800-822-7375) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 TLG/jrd Sincerely, ?l Mr. Thomas L. Gouker Manager of Collections PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street/ P.O. Box 15057 Harrisburg, PA 17105-5057 Pennsylvania Housing Finance Agency Accounting / Loan Servicing Division 211 North Front Street, P.O. Box 15057 Harrisburg, PA 1 71 05-505 7 (1-800-822-7375) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 NOTICE April 14, 2009 ISRAEL M RAMIREZ CHASITY J RAMIREZ 119 S LOCUST ST SHIREMANSTOWN, PA 17011-6733 RE: Account# 1527761 TO: ISRAEL M RAMIREZ CHASITY J RAMIREZ 119 S LOCUST ST SHIREMANSTOWN, PA 17011-6733 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY The Federal Housing and Development Act of 1987 (as amended) directs creditors to notify homeowners who are delinquent in their mortgage obligation of the availability of homeownership counseling provided by nonprofit organizations approved by the Secretary of the Department of Housing and Urban Development ("HUD") and experienced in the provision of homeownership counseling. Attached is a current list of HUD-approved counseling agencies for Pennsylvania. If these agencies are not near you, you can call HUD's toll free number (800) 569-4287 for financially distressed mortgagors for information concerning HUD-approved housing counseling agencies. Enclosure Housing Counseling List Pennsylvania Housing Finance Agency Accounting / Loan Servicing Division 211 North Front Street, P. 0. Box 15057 Harrisburg, PA 1 71 05-505 7 (1-800-822-7375) 01-(717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 * Please be sure the agency of your choice services your county. CCCS OF WESTERN PA-HARRISBURG NACA 2000 LINGLESTOWN RD. 1341 N DELAWARE AVE; SUITE 312 HARRISBURG, PA. 17110 PHILADELPHIA, PA. 19125 Phone: 888-599-2227 Phone: 888-297-5568 HOUSING ALLIANCE OF YORK 34 S. Duke St. York, PA 17401-1106 Phone: 800-864-4909 PHILADELPHIA COUNCIL OF COMMINITY DEVELOPMENT ONE PENN CENTER; 1617 JFK BLVD; SUITE 1550 PHILADELPHIA, PA. 19103-1828 Phone: 800-930-4663 TABOR COMMUNITY SERVICES 208 E King St. Lancaster, PA 17608-1676 Phone: 717-397-518? ? 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J 7160 3901 9848 1754 1219 TO: ISRAEL M RAMIREZ 119 S LOCUST ST SHIREMANSTOWN, PA 17011-6733 SENDER: CARTAGINA REFERENCE: 1527761 PS Form 3800, January 2005 RETURN Postage .58 RECEIPT Certified Fee 2.70 SERVICE Return Receipt Fee 2.20 Restricted Delivery Total Postage & Fees 5.48 US Postal Service POSTMARK OR DATE Receipt for Certified Mail ?to Insurance Coverage Provided Do tdol Use tar intarnaucr:al IA" VERIFICATION Anthony J. Julian hereby states that he is the Director of Accounting and Loan Servicing of the Pennsylvania Housing Finance Agency, mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Anthony J. J is Director of Accounting and Loan Servicing PENNSYLVAMN A FINANCE AGENCY Date: ?/Q SERVICING AGENT FOR U.S. BANK ASSOCIATION AS TRUSTEE FOR PEIVNSyL?A HOUSING FINANCE AGENCY 20019 ut.i. 30 {tI io' 1 L #, # /j ?6 l?k ? 1 ? l?il?r 7 Sheriffs Office of Cumberland County R Thomas Kline Sheriff 0%v of cua be't, Ronny R Anderson h? "0 Chief Deputy Jody S Smith r Civil Process Sergeant Edward L Schorpp Solicitor US Bank National Association vs. Chasity J. Ramirez Case Number 2009-4377 SHERIFF'S RETURN OF SERVICE 07/06/2009 08:13 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on July 6, 2009 at 2013 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Chasity J. Ramirez, by making known unto herself personally, defendant at 119 South Locust Street Shiremanstown, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 07/06/2009 08:13 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on July 6, 2009 at 2013 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Israel M. Ramirez, by making known unto Chasity J. Ramirez, wife of defendant at 119 South Locust Street Shiremanstown, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 07/06/2009 05:33 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: OCCUPANTS at 119 South Locust Street Shiremanstown, PA 17011, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant OCCUPANTS. SHERIFF COST: $73.94 SO ANSWERS, July 07, 2009 R THOMAS KLINE, SHERIFF i Depi;kj Sheri C,6 r- z' 4 ,K . 4: C-> ~? U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 MORTGAGE FORECLOSURE PR AECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) CHASITY J. RAMIREZ and ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiffs damages as follows: Unpaid Principal Balance $159,076.00 Interest $7,029.60 Per diem of $23.20 From 09/01/2008 To 07/01/2009 Accumulated Late Charges $463.24 Late Charges $325.44 ($36.16 per month to 07/01/2009) Escrow Deficit $1,128.67 5% Attorney's Commission $7,953.80 TOTAL $175,976.75 "Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff s Sale. PURCELL, KRUG & HALLER Leon P. Haller PA I.D. # 15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 DEFENDANT(S) IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 7 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF Vs. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, I hereby certify that on July 28, 2009 I served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. B Leon P. Haller PA I.D. # 15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4377 VS. CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ CIVIL ACTION LAW IN MORTGAGE FORECLOSURE Defendants DATE OF THIS NOTICE: July 28, 2009 TO: CHASITY J. RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 ISRAEL M. RAMIREZ A/KJA ISRAEL MEDINA RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & HALL LEON P. HALLER, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed LEON P. HALLER, ESQUIRE AJH OF PEN,: -ve-- NOTARIAL. SEAL MARYLAND K. FERRETTI, Notary Public Lower Paxton Twp. i Dauphin County My commission Expres Aug. S, 201 I before me this day of uo?20 OF THc AnTAPY 2009 AUG 2 I F 12 ? 9 PBNNS`k'I. JA",!!i4. # 14 . oo P 0 AI-N C& f'5 ? W U9577 Ooj? ?A" r -V% IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 09-4377 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) Total Judgment Amount $175,976.75 Interest $3,712.00 Per diem of $23.20 to sale date 12/9/2009 Late Charges $180.80 $36.16 per month to sale date 12/9/2009 Escrow Deficit $1,990.85 TOTAL WRIT $181,860.40 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, December 09, 2009 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned Date: August 19, 2009 Attorney for Plaintiff 1719 North Front Street Leon F. -Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 Date: -144zj 44 P OTHONOT RK CIVIL DIVISION BY DEPUTY 'ILI D-Oi FIC OF 7 PPOTI r;!,-N `OTARY 2009ViG 21 PM 12: 59 CUML ' 14.00 P 0 4"T' ? '13.84 CW '78.50 14.00 " a.50 „ - iga.g4 -Pp A-?+ $ a. 00 bus ,50 LL co (505Qa R * :95ll T? E ? °? U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011: Name and address of the Owner(s) or Reputed Owner(s): CHASITY J. RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 N. Front Street P. O. Box 8029 Harrisburg, PA 17105-8029 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are mad ubject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: August 19, 2009 OF THE FR--,ri 't"4! 2009 AUG 21 PH 12: - 9 CUm! C:{ {?,,1{{{{??117j yam/ U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, December 09, 2009 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 09-4377 JUDGMENT AMOUNT $175,976.75 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: CHASITY J. RAMIREZ and ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN house and lot of ground situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of South Locust Street, said point being 425.60 feet southeast of the Southeast corner of Locust Street and Parish Alley; thence along the line of a ten (10) foot wide private drive, North 70 degrees, 56 minutes, 10 seconds East, 124.62 feet to a point; thence along the line of Lot No. 2B as shown on the hereinafter mentioned Plan of Lots, South 19 degrees, 03 minutes, 50 seconds East, 76.61 feet to a point; thence along the line of Lot No. 1 on said Plan, South 65 degrees, 07 minutes, 00 seconds West, 108.29 feet to a point on the East side of South Locust Street, aforesaid; thence along said side of South Locust Street, North 29 degrees, 58 minutes, 00 seconds West, 89.19 feet to a point, the place of BEGINNING. BEING Lot No. 2A on the final subdivision plan of Herbert Benner, which said Plan is recorded in the Cumberland County Recorder's offices in Plan Book No. 24, at page 20. HAVING THEREON ERECTED A DWELLING KNOWN AS 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 BEING THE SAME PREMISES WHICH Charles W. Keck and Veronica M. Keck, his wife, by deed dated 2/26/07 and recorded 3/1/07 in Cumberland County Record Book 278, Page 4764 granted and conveyed until Israel M. Ramirez and Chasity J. Ramirez. The said Israel M. Ramirez is a/k/a Israel Medina Ramirez. ASSESSMENT NO. 37-23-0555-271B. UNDER AND SUBJECT to the right of the owners of Lot 2B as shown on the aforesaid plan to enter onto the premises herein conveyed for the purpose of servicing and maintaining a sewer line relocated and constructed on the premises herein conveyed, provided however the cost of servicing and maintaining said sewer line shall not be deemed to be the responsibility of the Grantees herein, their heirs and assigns. ALSO UNDER AND SUBJECT, NEVERTHELESS, to all easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal. TO BE SOLD AS THE PROPERTY OF CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ ON JUDGMENT NO. 09-4377 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-4377 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, Trustee for THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff (s) From CHASITY J. RAMI"Z, ISREAL M. RAMIREZ a/k/a ISRAEL MEDINA RAMIREZ (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 gamishee(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 $175,976.75 L.L. $.50 Interest per diem of $23.20 to sale date 12/9/09 -- $3,712.00 Atty's Comm % Due Prothy $2.00 Atty Paid $192.94 Other Costs: Late Charges: $36.16 per month to sale date 12/9/09 -- $180.80 Escrow Deficit: -- $1,990.85 *plus additional interest, late charges and other costs to date of sheriffs sale Plaintiff Paid Date: 8/21/09 urns R. 51o 6onary (Seal) By: REQUESTING PARTY: Name: LEON P. HALLER, ESQUIRE Address: PURCELL, KRUG & HALLER Deputy 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 115.1f 12.() O C , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: CHASITY J. RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 Pennsylvania Housing Finance Agency 211 N. Front Street P. O. Box 8029 Harrisburg, PA 17105-8029 By PURCELL, KRUG & HA R Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES HOWARD B. KRUG LEON P. HALLER JOHN W.PURCELLJR. JILL M. WINKA BRIAN J. TYLER NICHOLE M. STALEY O'GORMAN CHASITY J. RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234A 178 FAX (717) 234-1206 Pennsylvania Housing Finance Agency 211 N. Front Street P. O. Box 8029 Harrisburg, PA 17105-8029 HERSHEY (717)533-3836 JOSEPH NISSLEY (1910-1982) JOHN W.PURCELL VALERIE A. GUNNOF COUNSEL NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by bei ified of said Sheriffs Sale. B. Leon P. Haller PA I.D.15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, December 09, 2009 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 09-4377 JUDGMENT AMOUNT $175,976.75 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: CHASITY J. RAMIREZ and ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN house and lot of ground situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of South Locust Street, said point being 425.60 feet southeast of the Southeast corner of Locust Street and Parish Alley; thence along the line of a ten (10) foot wide private drive, North 70 degrees, 56 minutes, 10 seconds East, 124.62 feet to a point; thence along the line of Lot No. 2B as shown on the hereinafter mentioned Plan of Lots, South 19 degrees, 03 minutes, 50 seconds East, 76.61 feet to a point; thence along the line of Lot No. 1 on said Plan, South 65 degrees, 07 minutes, 00 seconds West, 108.29 feet to a point on the East side of South Locust Street, aforesaid; thence along said side of South Locust Street, North 29 degrees, 58 minutes, 00 seconds West, 89.19 feet to a point, the place of BEGINNING. BEING Lot No. 2A on the final subdivision plan of Herbert Benner, which said Plan is recorded in the Cumberland County Recorder's offices in Plan Book No. 24, at page 20. HAVING THEREON ERECTED A DWELLING KNOWN AS 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 BEING THE SAME PREMISES WHICH Charles W. Keck and Veronica M. Keck, his wife, by deed dated 2/26/07 and recorded 3/1/07 in Cumberland County Record Book 278, Page 4764 granted and conveyed until Israel M. Ramirez and Chasity J. Ramirez. The said Israel M. Ramirez is a/k/a Israel Medina Ramirez. ASSESSMENT NO. 37-23-0555-271B. UNDER AND SUBJECT to the right of the owners of Lot 2B as shown on the aforesaid plan to enter onto the premises herein conveyed for the purpose of servicing and maintaining a sewer line relocated and constructed on the premises herein conveyed, provided however the cost of servicing and maintaining said sewer line shall not be deemed to be the responsibility of the Grantees herein, their heirs and assigns. ALSO UNDER AND SUBJECT, NEVERTHELESS, to all easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal. TO BE SOLD AS THE PROPERTY OF CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ ON JUDGMENT NO. 09-4377 7160 3901 9848 2032 8821 T: CHASITY J. RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 SENDER: NOS 12/09/09 REFERENCE: PHFA/RAMIREZ RETURN Ertified vu RECEIPT Fee SERVICE m Receipt Fas icted Delivery Postage & Fees us Postal SOM108 Receipt for Certified Mail No Insurance 00vera9e Provided Do Not Use for International Mall fAA ?tp? ?J m 0 N N L Vo Insurance Coverage Provided lp Do Not use for international Mail S 7160 3901 9848 2032 8869 TO: ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 SENDER: NOS 12/09/09 REFERENCE: PHFA/RAMIREZ RETURN 7P0=90 RECEIPT Fee SERVICE ecept Fee Total Postage & Fees US Postal Service Receipt for Certified Mail co N .L- PENNSYLVANIA HOUSING FINANCE AGENCY v. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ Cumberland County Sale 12/9/2009 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: CHASITY J. RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 CP e PITNEY B05NE5 02 W $ 01.15° 0004284324 AUG28 2009 MAILED FROM ZIP CODE 1 71 02 PENNSYLVANIA HOUSING FINANCE AGENCY v. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ Cumberland County Sale 12/9/2009 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: TENANT/OCCUPANT 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Pennsylvania Housing Finance Agency 211 N. Front Street P. O. Box 8029 Harrisburg, PA 17105-8029 X" WTIYTY BOWTS 02 1M $ 02.300 0004284324 A.UG28 2OQ9 MAILED FROM ZIP CODE 1 71r FILL i TH Uinl ? f ?l i ti v ., <??!1 hpA t Ci'il z LVA N7i SHERIFF'S OFFICE OF CUMBERLAND COUNTY RonnyRAnderson F'!-r ~ .-;,~,,., Sheriff _ r-,. ~, t Jody S Smith ``~~~~~~~~ a;~~~'~¢ 1090FEB 25 PM 2~ ~ I Chief Deputy Edward L Schorpp Solicitor ~._ , US Bank National Association vs. Chasity J. Ramirez (et al.) Case Number 2009-4377 SHERIFF'S RETURN OF SERVICE 10/02/2009 06:55 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 at 1855 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 Chasity J. Ramirez & Israel M. Ramirez, located at 119 South Locust Street, Shiremanstown, Cumberland County, Pennsylvania according to law. 10/02/2009 06:55 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 at 1855 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: Chasity J. Ramirez, by making known unto, Chasity J. Ramirez, personally, at 119 South Locust Street, Shiremanstown, 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 06:55 PM -Israel M. Ramirez, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 at 1855 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: Israel M. Ramirez, by making known unto, Chasity J. Ramirez, adult in charge, at 119 South Locust Street, Shiremastown, Cumberland County Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 12/04/2009 Property sale postponed to 3/3/2010. 02/25/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, per letter of instruction from Attorney Haller. `;,~, SHERIFF COST: $1,003.78 SO?~"" a.. _q .' r~" #1 February 25, 2010 R NY R ANDERSON, SHERiFFy ~ ~--U~ (o L 3 ;5~ ~" ~ ~~~~y ~ ~ 9~' ~~ ~ ~~~~ 4 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011: Name and address of the Owner(s) or Reputed Owner(s): CHASITY J. RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 ISRAEL M. RAMIREZ A/K1A ISRAEL MEDINA RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 N. Front Street P. O. Box 8029 Harrisburg, PA 17105-8029 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are mad ubject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities ~~ Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 1.7102 (717) 234-4178 DATE: August 19, 2009 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, December 09, 2009 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 09-4377 JUDGMENT AMOUNT $175,976.75 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: CHASITY J. RAMIREZ and ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained front the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office -Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN house and lot of ground situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of South Locust Street, said point being 425.60 feet southeast of the Southeast corner of Locust Street and Parish Alley; thence along the line of a ten (10) foot wide private drive, North 70 degrees, 56 minutes, 10 seconds East, 124.62 feet to a point; thence along the line of Lot No. 2B as shown on the hereinafter mentioned Plan of Lots, South 19 degrees, 03 minutes, 50 seconds East, 76.61 feet to a point; thence along the line of Lot No. 1 on said Plan, South 65 degrees, 07 minutes, 00 seconds West, 108.29 feet to a point on the East side of South Locust Street, aforesaid; thence along said side of South Locust Street, North 29 degrees, 58 minutes, 00 seconds West, 89.19 feet to a point, the place of BEGINNING. BEING Lot No. 2A on the final subdivision plan of Herbert Benner, which said Plan is recorded in the Cumberland County Recorder's offices in Plan Book No. 24, at page 20. HAVING THEREON ERECTED A DWELLING KNOWN AS 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 BEING THE SAME PREMISES WHICH Charles W. Keck and Veronica M. Keck, his wife, by deed dated 2/26/07 and recorded 3/1/07 in Cumberland County Record Book 278, Page 4764 granted and conveyed until Israel M. Ramirez and Chasity J. Ramirez. The said Israel M. Ramirez is a/k/a Israel Medina Ramirez. ASSESSMENT NO. 37-23-0555-271B. UNDER AND SUBJECT to the right of the owners of Lot 2B as shown on the aforesaid plan to enter onto the premises herein conveyed for the purpose of servicing and maintaining a sewer line relocated and constructed on the premises herein conveyed, provided however the cost of servicing and maintaining said sewer line shall not be deemed to be the responsibility of~ the Grantees herein, their heirs and assigns. ALSO UNDER AND SUBJECT, NEVERTHELESS, to all easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal. TO BE SOLD AS THE PROPERTY OF CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K1A ISRAEL MEDINA RAMIREZ ON JUDGMENT NO. 09-4377 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY` OF CUMBERLAND) NO 09-4377 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, Trustee for THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff (s) From CHASITY J. RAMIREZ, ISREAL M. RAMIREZ a/k/a ISRAEL MEDINA RAMIREZ (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 $175,976.75 L.L. $.50 Interest per diem of $23.20 to sale date 12/9/09 -- $3,712.00 Atty's Comm % Due Prothy $2.00 Atty Paid $192.94 Other Costs: Late Charges: $36.16 per month to sale date 12/9/09 -- $180.80 Escrow Deficit: -- $1,990.85 *plus additional interest, late charges and other costs to date of sheriff s sale Plaintiff Paid Date: 8/21/09 (Seal) Curtis R. , Protho tary By: Deputy REQUESTIIti'G PARTY: Name: I~F,ON P. HALLER, ESQUIRE Address: PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 Real Estate Sale # On September 9, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Borough of Shiremanstown, Cumberland County, PA Known and numbered as, 119 South Locust Street, Shiremanstown, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 9, 2009 By: B C ' Real Estate Coordi a or J-. '~y- 11 °'; '~ <! j~, ; `E%> 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. G~G ;<sa Marie Coyne,~'ditor SWORN TO AND SUBSCRIBED before me this 6 da of November 2009 Notary N07ARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNiY My Commission Expires Apr 2H, 2010 Writ No. 2009-4377 Civil U.S. Bank, National Association Trustee for the Pennsylvania Housing Finance Agency vs. Chastity J. Ramirez, Isreal M. Ramirez a/k/a Isreal Medina Ramirez Atty: Leon Haller ALL THAT CERTAIN house and lot of ground situate in the Borough of Shiremanstown, County of Cumber- land and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of South Locust Street, said point being 425.60 feet southeast of the Southeast corner of Locust Street and Parish Alley; thence along the line of a ten (10) foot wide private drive, North 70 degrees, 56 minutes, 10 seconds East, 124.62 feet to a point; thence along the line of Lot No. 2B as shown on the hereinafter mentioned Plan of lots, South 19 de- grees, 03 minutes, 50 seconds East, 76.61 feet to a point; thence along the line of Lot No. 1 on said Plan, South 65 degrees, 07 minutes, 00 seconds West, 108.29 feet to a point on the East side of South Locust Street, aforesaid; thence along said side of South Locust Street, North 29 degrees, 58 minutes, 00 seconds West, 89.19 feet to a point, the place of BEGINNING. BEING Lot No. 2A on the final subdivision plan of Herbert Benrier, which said Plan is recorded in the Cumberland County Recorder's of- fices in Plan Book No. 24, at page 20. HAVING THEREON ERECTED a dwelling known as 119 South Locust Street Shiremanstown, PA 17011 BEING THE SAME PREMISES WHICH Charles W. Keck and Ve- ronica M. Keck, his wife, by deed dated 2/26/07 and recorded 3/ 1 /07 in Cumberland County Record Book 278, Page 4764 granted and con- veyed until Israel M. Ramirez and Chasity J. Ramirez. The said Israel M. Ramirez is a/k/a Israel Medina Ramirez. ASSESSMENT NO. 37 1B. UNDER AND SUBJECT to the right of the owners of Lot 2B as shown on the aforesaid plan to enter onto the premises herein conveyed for the purpose of servicing and maintaining a sewer line relocated and constructed on the premises herein conveyed, provided however the cost of servicing and maintaining said sewer line shall not be deemed to be the responsibility of the Grantees herein, their heirs and assigns. ALSO UNDER AND SUBJECT, NEVERTHELESS, to all easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal. TO BE SOLD AS THE PROPERTY OF Ci-Jasity J. Ramlrez and Is- rael M. Ramirez a/k/a Israel Medina Ramirez on Judgment No. 09-4377. ~ The Patriot-News Co. X12 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c'tl~e~latriot 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 ofFce 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 10/30/09 11 /06/09 ~~~ . .~-: .... Sworn to and subscribed before me this 16 ay,e~f November, 2009 A.D. 1' 1 1 C 1: ~- ~r \. ~ i r .; ~ ~-~ . ___ Notafy Public COM-V-pNyyEALTF{ OF pENfeISYLVANI.A PJotariai Spa) Sheer L. Kisnpr, Notary i~ublic City OF Namsburr~, Dauptrin County MY Commission Eaq~irps Nov. 26, 2011 Member, Pennsviyan~~ Q ~atian of fVotariLs WtIC No. 2001.1377 Clvil Tarn U:$. Sank, National Aesociatbn 7-,fst« for the wnneyn-anle Housing Finance Agsncy Vs Chastity J: fiettnirez Isresi M. Ramlrsz, d~/a Isreal Medlna F1f>imirsz Arty: Leon Haller ALL THAT CERTAIN horse and lot of ground situate in the Borough of Shiremanstown, County of Cumberland .and State of Pennsylvania, more paRiculariy bouhded and described as fopows, to wit: BEGINNING at a poim "on dte East side of South Locust Street,. said point being 425.60 feet southeast of the Southeast comer of Locust Street and Parish Alley; thence along the line of a ten (10) fdot wide: pevate drive, North 70 degrees, 6 minutes, 10 se<wnds East, 124.62 feet to a point; thence along the line of Lot No. 2B as shown on the hereinafter mentioned plea of Lots, South 14 degrees, 03 minutes, 50 seconds East, 76.61 feet to a point; thence along the line of Lot No. 1 on said Plan, South 65 degrees, 07 minutes, 00 sewnds West 108.29 feet to a point on the East side of South Locust Street, aforesaid; thence along said side of South Locust Street, North 29 degrees, SS .minutes, 00 seconds West, 89.19 feet to a point, the place of IIEGIIJNING: BEING Lot No. 2A oa.the final.subdivision plan of Herbert Benria; which said Plan is tecbrded in the Cumberland County Recarda's offices in Plan Book No. 24, at page 20. HAVING THEREON ERECTED A DWELLING KNOWN AS li9 SOUTH LOCUST STREET SH»tEhIANSTOWN, PA 17011 BEING THE SAME PREMISES WHICH Charles W, Keck and Veronica M. Kxk, his wife, by deed dated 2f261U7 and recorded 3/1107 in Cumbaland Co®ty Record Book 278. Page 4764 granted and c~veyed urRit Lgtael M. Ramirez.and.Chasity,J..Ramiircc. saiblsrael. M. Ramirez is ahlaTstsellta Ramita. ASSESSMENT N0.371$. UNDER AND. SUBJECT to the right of the owners of Lot ZB as shown on the aforesaid plan to enter ante, the premises herein conveyed for the purpose, o#'servicing and maintaining a sewer line relocated and wos4ucted on the premises herein conveyed, provided however the cost of servicing and' maintaining said sews line shall not be darned to be the :responsibility of the Grantees herein, thou hems and assigns. ALSO UNDER- AND $UBJECT, NEYERTHELES$, to all easements, restrictions, encumbrancxs snd other matters of record of that which a physical inspection or srkvey of the premises would reveal. TO BE SOLD AS ,T#~E PROPERTY OF CI- iAS1TY I. RAMIREZ AND ISRAEL M: RAMBtEZ A/IUA ISRAEL MEDIIVA RAMIliFZ ON JIJDOME,NT N0.09-4377 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 09-4377 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF V'S. CHASITY J ISRAEL M. RAMIREZ, RAMIREZ AND RAMIREZ A/IUA ISRAEL MEDINA Total Judgment Amount $175,976.75 Interest $5,850.80 Per diem of $23.20 to sale date 6/6/12 Late Charges $976.32 $36.16 per month to sale date 6/6/12 Escrow Deficit $1,985.82 TOTAL WRIT $184,789.69 DEFENDANT(S) *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, December 09, 2009 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid _ Due Proth/Cierk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: C i rnn one s . Issue Writ of Execution in the above capt ? „ = u ?? N Q?'r Date: February 13, 2012 z Attorney for Plaintiff ?cc:) ... 1719 North Front Street eon P. Haller Trz p Harrisburg, PA 17102 PA I.D. #15700 ..4? ut ?' (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: SS To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached. description known as 119 SOUTH LOCUST STREET N, PA 17011 SHIREMANSTOQ5) Date: 4&8.50 PA A'r-rV 75. 94 0,13F PROTHONOTARY/CLERK CIVIL DIVISION 1,003.178 78- so 14 - oo BY A. oo _?-- DEPUTY I,aaa.7a- po AR-/ *a.as tue- 0-0 C-# 1'14188 e?a?la?s P (k)ri+ 4awd ALL THAT CERTAIN house and lot of ground situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of South Locust Street, said point being 425.60 feet southeast of the Southeast corner of Locust Street and Parish Alley; thence along the line of a ten (10) foot wide private drive, North 70 degrees, 56 minutes, 10 seconds East, 124.62 feet to a point; thence along the line of Lot No. 213 as shown on the hereinafter mentioned Plan of Lots, South 19 degrees, 03 minutes, 50 seconds East, 76.61 feet to a point; thence along the line of Lot No. 1 on said Plan, South 65 degrees, 07 minutes, 00 seconds West, 108.29 feet to a point on the East side of South Locust Street, aforesaid; thence along said side of South Locust Street, North 29 degrees, 58 minutes, 00 seconds West, 89.19 feet to a point, the place of BEGINNING. BEING Lot No. 2A on the final subdivision plan of Herbert Benner, which said Plan is recorded in the Cumberland County Recorder's offices in Plan Book 24, Page 20. HAVING THEREON ERECTED A DWELLING KNOWN AS 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 BEING THE SAME PREMISES WHICH Charles W. Keck and Veronica M. Keck, his wife, by deed dated 2/26/07 and recorded 3/1/07 in Cumberland County Record Book 278, Page 4764 granted and conveyed until Israel M. Ramirez and Chasity J. Ramirez. The said Israel M. Ramirez is a/k/a Israel Medina Ramirez. ASSESSMENT NO. 37-23-0555-271B. UNDER AND SUBJECT to the right of the owners of Lot 2B as shown on the aforesaid plan to enter onto the premises herein conveyed for the purpose of servicing and maintaining a sewer line relocated and constructed on the premises herein conveyed, provided however the cost of servicing and maintaining said sewer line shall not be deemed to be the responsibility of the Grantees herein, their heirs and assigns. ALSO UNDER AND SUBJECT, NEVERTHELESS, to all easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal. TO BE SOLD AS THE PROPERTY OF CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDIN A RAMIREZ ON JUDGMENT NO. 09-4377 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE BANI92UPTCY DISMISSAL . ti IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: ISRAEL M. RAMIREZ CHASITY J. RAMIREZ Debtor(s) CHARLES J DEHART, III Movant(s) vs. ISRAEL M. RAMIREZ : CHASITY J. RAMIREZ Respondent(s) Chapter: 13 Case Number: 1:09-bk-09298RNO ORDER DISMISSING CASE Upon consideration of the Trustee's Certificate of Default of Stipulation in settlement of the Trustee's prior Motion to Dismiss case for material default and it having been determined that this case should be dismissed, it is ORDERED that the above-named case of the debtor(s) be and it hereby is dismissed. By the Court, L.A u. oa4 3r Roben N. Opel, II, Bankruptcy Judge cno Dated: October 31, 2011 MDPA-Dismiss Casa.WPT - REV 03/09 Case 1:09-bk-09298-RNO Doc 79 Filed 10/31/11 Entered 10/31/11 11:50:20 Desc Main Document Pane 1 of 1 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ AWA ISRAEL MEDINA RAMIREZ, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT -n COMMONWEALTH OF PENNSYLVANIA C° ?-? --4 SS 's p.C= .. m COUNTY OF DAUPHIN -- + ' :v ? Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before m this day of 20/1 HALLER, ESQUIRE Oi"AMQNWEALTH OF PENN NIA TARIAL SEAL 7ERRETTi.Notary Public :.,.. _ °zJj?. Dauphin County > { ..,.,;issicn Expires Aug. 8, 2014 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011: 1. Name and address of the Owner(s) or Reputed Owner(s): C") cz -n Mayo -" =-n CHASITY J. RAMIREZ zrn ev rnr 119 SOUTH LOCUST STREET cn? N r" SHIREMANSTOWN, PA 17011 r-z ? ' 3> = ISRAEL M. RAMIREZ A/K/A aC o ISRAEL MEDINA RAMIREZ z -? 119 SOUTH LOCUST STREET -? vn SHIREMANSTOWN, PA 17011 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 Michael S. Travis, Esquire 3904 Trindle Road Camp Hill, PA 17011 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein. are flAdq subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authort' Leon aller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:February 13, 2012 4 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE DEFENDANT(S) NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, December 09, 2009 rnm ' te n _ r` t/) N M CG-J i" 0 2 a 3 C. ) -e CT TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 09-4377 JUDGMENT AMOUNT $175,976.75 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: CHASITY J. RAMIREZ and ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-4377 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, Trustee for THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff (s) From CHASITY J. RAMIREZ and ISRAEL M. RAMIREZ a/k/a ISRAEL MEDINA RAMIREZ (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: $175,976.75 L.L.: Interest per diem of $23.20 to sale date 6/6/12 - $5,850.80 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $1,222.72 Other Costs: Late Charges: $36.16 per month to sale date 6/6/12 -- $976.32 Escrow Deficit: $1,985.82 Plaintiff`Piiid: . Date`: 2121/12 David D. Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name: LEON P. HALLER, ESQUIRE Address: PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor E4;-r US Bank Trust National Association vs. Case Number Chasity J. Ramirez (et al.) 2009-4377 SHERIFF'S RETURN OF SERVICE 03/19/2012 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: $63.95 SO ANSWERS, eoo?l?, ('?Z, N, Z March 20, 2012 RON R ANDERSON, SHERIFF t- r-n -7C -? r'n M ?• r i-= "'771 a :.n v r- X- --? < CD -0 CD _r 7 (ci GouirySui[e Sheriff 7eieosoft. Inc. COPY U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW VS. CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) NO. 09-4377 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011: Name and address of the Owner(s) or Reputed Owner(s): CHASITY J. RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 Michael S. Travis, Esquire 3904 Trindle Road Camp Hill, PA 17011 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorit' Leon . aller PA 1. D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: February 13, 2012 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ AWA ISRAEL MEDINA RAMIREZ, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 094377 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, December 09, 2009 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 09-4377 JUDGMENT AMOUNT $175,976.75 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: CHASITY J. RAMIREZ and ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN house and lot of ground situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of South Locust Street, said point being 425.60 feet southeast of the Southeast corner of Locust Street and Parish Alley; thence along the line of a ten (10) foot wide private drive, North 70 degrees, 56 minutes, 10 seconds East, 124.62 feet to a point; thence along the line of Lot No. 2B as shown on the hereinafter mentioned Plan of Lots, South 19 degrees, 03 minutes, 50 seconds East, 76.61 feet to a point; thence along the line of Lot No. 1 on said Plan, South 65 degrees, 07 minutes, 00 seconds West, 108.29 feet to a point on the East side of South Locust Street, aforesaid; thence along said side of South Locust Street, North 29 degrees, 58 minutes, 00 seconds West, 89.19 feet to a point, the place of BEGINNING. BEING Lot No. 2A on the final subdivision plan of Herbert Benner, which said Plan is recorded in the Cumberland County Recorder's offices in Plan Book 24, Page 20. HAVING THEREON ERECTED A DWELLING KNOWN AS 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 BEING THE SAME PREMISES WHICH Charles W. Keck and Veronica M. Keck, his wife, by deed dated 2/26/07 and recorded 3/1/07 in Cumberland County Record Book 278, Page 4764 granted and conveyed until Israel M. Ramirez and Chasity J. Ramirez. The said Israel M. Ramirez is a/k/a Israel Medina Ramirez. ASSESSMENT NO. 37-23-0555-271B. UNDER AND SUBJECT to the right of the owners of Lot 2B as shown on the aforesaid plan to enter onto the premises herein conveyed for the purpose of servicing and maintaining a sewer line relocated and constructed on the premises herein conveyed, provided however the cost of servicing and maintaining said sewer line shall not be deemed to be the responsibility of the Grantees herein, their heirs and assigns. ALSO UNDER AND SUBJECT, NEVERTHELESS, to all easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal. TO BE SOLD AS THE PROPERTY OF CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ ON JUDGMENT NO. 09-4377 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY PH 12: PENt4,,? 'Lkl,tiIt US Bank Trust National Association vs. Case Number Chasity J. Ramirez (et al.) 2009-4377 SHERIFF'S RETURN OF SERVICE 03/19/2012 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: $63.95 SO ANSWERS, 671 , - -May 25, 2012 RON ? R ANDERSON, SHERIFF !-ou;?1 o 1te : m^ ,I f ? e _ ::oft. [ne U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHASITY J. RAMIREZ AND ISRAEL M. RAMIIREZ A/K/A ISRAEL MEDINA RAMIREZ, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-4377 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, December 09, 2009 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE P40PERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 09-4377 JUDGMENT AMOUNT $175,976.75 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: CHASITY J. RAMIREZ and ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ A SC14EDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas !:of the within County at the Courthouse address specified herein. THIS gAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS 13EEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST IT MAX', CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO P You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL;, ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc $ Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You ,may file a petition with the Court of Common Pleas of the within County to open the judgment if yo4 have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or th'le procedure used against you. 2. After, the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set side the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be present?d to the Court of Common Pleas of the within County. The petition must be served on the attorney for!,the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN house and lot of ground situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of South Locust Street, said point being 425.60 feet southeast of the Southeast corner of Locust Street and Parish Alley; thence along the line of a ten (10) foot wide private drive, Forth 70 degrees, 56 minutes, 10 seconds East, 124.62 feet to a point; thence along the line of Lot No. '213 as shown on the hereinafter mentioned Plan of Lots, South 19 degrees, 03 minutes, 50 seconds East, 76.61 feet to a point; thence along the line of Lot No. 1 on said Plan, South 65 degrees, 07 minutes, 00 seconds West, 108.29 feet to a point on the East side of South Locust Street, aforesaid; thence along said side of South Locust Street, North 29 degrees, 58 minutes, 00 seconds West, 89.19 feet to a point, the place of BEGINNING. BEING Lot NO. 2A on the final subdivision plan of Herbert Benner, which said Plan is recorded in the Cumberland County Recorder's offices in Plan Book 24, Page 20. HAVING THEREON ERECTED A DWELLING KNOWN AS 119 SOUTH LOCUST STREET SHIREMANSTOWN, PA 17011 BEING THE SAME PREMISES WHICH Charles W. Keck and Veronica M. Keck, his wife, by deed dated 2/26/07 and recorded 3/1/07 in Cumberland County Record Book 278, Page 4764 granted and conveyed until Israel M. Ramirez and Chasity J. Ramirez. The said Israel M. Ramirez is a/k/a Israel Medina Ramirez. ASSESSMENT NO. 37-23-0555-271B. UNDER AND SUBJECT to the right of the owners of Lot 2B as shown on the aforesaid plan to enter onto the premises herein conveyed for the purpose of servicing and maintaining a sewer line relocated and constructed on the premises herein conveyed, provided however the cost of servicing and maintaining said sewer line shall not be deemed to be the responsibility of the Grantees herein, their heirs and assign. ALSO UNDERI, AND SUBJECT, NEVERTHELESS, to all easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal. TO BE SOLD AS THE PROPERTY OF CHASITY J. RAMIREZ AND ISRAEL M. RAMIREZ A/K/A ISRAEL MEDINA RAMIREZ ON JUDGMENT NO. 09-4377 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-4377 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, Trustee for THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff (s) From CHASITY J. RAMIREZ and ISRAEL M. RAMIREZ a/k/a ISRAEL MEDINA RAMIREZ (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: $175,976.75 L.L.: Interest per diem of $23.20 to sale date 6/6/12 -- $5,850.80 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $1,222.72 Other Costs: Late Charges: $36.16 per month to sale date 6/6/12 -- $976.32 Escrow Deficit: $1,985.82 Plaintiff Paid: Date: 2/21/12 David D. Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name: LEON P. HALLER, ESQUIRE Address: PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney fbr: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 TRUE COPY FROM RECORD In Testimony whereof, 1 here unto se: my hand and the seal of said Co at CarlWe, Pa. This I,-* z ri 2G ! oZ ? P rothonotary On March 2, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Shiremanstown Borough, Cumberland County, PA, known and numbered 119 South Locust Street, Shiremanstown, PA 17011 more fully described on Exhibit"A" filed with this writ and by this reference incorporated herein. Date: March 2, 2012 By: For Claudia Brewbaker, Real Estate Coordinator