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Home My WebLink About09-8230Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 221613 WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. LEON G. RAMSEY, JR A/K/A LEON RAMSEY TRACY RAMSEY F/K/A TRACY BOONE 839 NORTH WEST STREET CARLISLE, PA 17013-1435 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM G ,ti I NO. 0 7, ?? A-j CUMBERLAND COUNTY File #: 221613 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 221613 1. Plaintiff is WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: LEON G. RAMSEY, JR A/K/A LEON RAMSEY TRACY RAMSEY F/K/A TRACY BOONE 839 NORTH WEST STREET CARLISLE, PA 17013-1435 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 04/15/2008 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR LEND AMERICA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200824514. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(8); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 221613 6 The following amounts are due on the mortgage: Principal Balance $124,358.54 Interest $6,832.76 02/01/2009 through 11/20/2009 (Per Diem $23.32) Attorney's Fees $1,300.00 Cumulative Late Charges $162.60 04/15/2008 to 11/20/2009 Property Inspections $15.00 Mortgage Insurance Premium / $101.28 Private Mortgage Insurance Cost of Suit and Title Search %-5-50-00 Subtotal $133,320.18 Escrow Credit $0.00 Deficit $1,138.22 Subtotal $1,139-22 TOTAL $134,458.40 7. If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriff s Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is nat seeking a judgment of personal liability (or an in ners? onam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 221613 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 10. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured- WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $134,458.40, together with interest from 11/20/2009 at the rate of $23.32 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: ? Lawrence T. Phelan, Esq., Id. No. 32227 9francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 221613 LEGAL DESCRIPTION ALL THAT CERTAIN Lot OR GROUND SITUATE IN THE BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE West BY North West Street; ON THE North BY Lot NO. 1, BLOCK 21 ON THE HEREINAFTER MENTIONED Plan OF Lots; ON THE East BY A 16 FOOT WIDE ALLEY; AND ON THE South BY PROPERTY NOR OR FORMERLY OF MRS. SUSAN MORRISON; CONTAINING 25 FEET IN FRONT ON SAID West North Street AND EXTENDING IN DEPTH AN EVEN WIDTH 190 FEET TO THE AFORESAID ALLEY, AND BEING Lot NO. 2, BLOCK 21, IN A Plan OF Lots LAID OUT BY THE CARLISLE LAND AND IMPROVEMENT COMPANY, WHICH Plan IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN MISC. BOOK 11, PAGE 572. SAID Lot OF GROUND HAS THEREON ERECTED A TWO AND ONEHALF STORY FRAME DWELLING HOUSE AND NECESSARY OUTBUILDINGS KNOWN AS 839 North West Street. PREMISES BEING: 839 NORTH WEST STREET PARCEL #: 06-19-1643-243. File #: 221613 The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: #/,t V Attorney for Plaintiff File #: 221613 S Fll -7,R 644- ??y .~ Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Wells Fargo Bank, NA vs. Leon G. Ramsey (et al.) ~,~~yµt+' of ~1t~rtbrr/,r~ ti.+ (~ ~~-.~ ~~r ~~. _ ', ~ i .._!' _ . Case Number 2009-8230 SHERIFF'S RETURN OF SERVICE 04/07/2010 09:37 AM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on 4/7/10 at 937 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 Leon G. Ramsey and Tracy Ramsey, located at, 839 North West Street, Carlisle, Cumberland County, Pennsylvania according to law. 04/08/2010 07:47 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 4/8/10 at 1945 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: Tracy Ramsey, by making known unto, Tracy Ramsey, personally, at, 839 North West Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 04/08/2010 07:47 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 4/8/10 at 1945 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: Leon G. Ramsey, by making known unto, Tracy Ramsey, Spouse, at, 839 North West Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 04/23/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Schmieg on 4/21/10 SHERIFF COST: $666.98 SO ANSWERS, May 21, 2010 RON R ANDERSON, SHERIFF ~! Coic;iySuite Sne~~n. ielebs;if. In.,;. ~~z~ `,7fr, l~ 1 WELLS FARGO.BANK, N.A.' COURT OF COMMON PLEAS Plaintiff , CIVIL DIVISION v. NO. ID9-8230 CIVIL TERM LEON G. RAMSEY, JR A/K/A LEON RAMSEY . TRACY RAMSEY F/K/A TRACY BOONE CUMBERLAND COUNTY Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 839 NORTH WEST STREET, CARLISLE, PA 17013-1435. 1. Name and address of Owner(s) or reputed Owner(s): Name LEON G. RAMSEY, JR A/K/A LEON RAMSEY .TRACY RAMSEY F/K/A TRACY BOO'NE 2. ~ ' Name-and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) ''" 112 E NORTH ST CARLISLE, PA 17013-2430 839 NORTH WEST STREET ", CARLISLE, PA 17013-1435 Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE ~. _. _;~ 3 ~ 'Name and last lcnowr`~ddress of every judgment creditor whose judgment is a record lien on the real property to be'sold: ~- ' ` ' - 'Name Address (if address cannot be reasonably ascertained, please indicate) Nohe 4. Name and address of last recorded holder of every mortgage of record: Name'' Address (if address cannot be ' ~' reasonably ascertained, please indicate) None: 5. Name and address of every other person who has any record lien on the property: Name ~ ~ Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of'every other person who has any record interest in the property and whose interest may be' affecte`d~~by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) ~.,. None. 7. Name and address ofevery other person of whom the plaintiff has knowledge who has an.y interest in the property which may be affected by the sale: Name Address (if address cannot be reasonabl a t i d l i di y scer a ne , p ease n cate) TENANTIOCCUPANT 839 NORTH WEST STREET CARLISLE, PA 17013-1435 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 United States Internal Revenue 13th Floor, Suite 1300 Special Procedures Branch 1001 Liberty Avenue Federated Investors Tower Pittsburgh, PA 15222 U.S. Department of Justice Federal Building, P.O. Box 11754 U.S. Attorney for the Middle District of PA 228 Walnut Street " ~'~" Harrisburg, PA 17108 Commonwealth of Pennsylvania 6"' Floor, Strawberry Sq., Dept 28061 Bureau of Individual Tax Harrisburg, PA 17128 Inheritance Tax Division Internal Revenue Service 13TH Floor, Suite 1300 Federated Investors'Tower 1001 Liberty Avenue Pittsburgh, PA 15222 Department of Public Welfare P.O. Box 8486 TPL Casualty Unit ` ` ` Willow Oak Building Estate Recovery Program Harrisburg, PA 17105 I verify that the s(atements made in this affidavit are true and correct to the lbest of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. March 5.2010 By. ~ Atto y or Plaintiff P elan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 - ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ,. ^ Vivek Srivastava, Esq., Id. No. 202331 :, ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ~ ` `~' `` ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. !0134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 f- WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. N0.09-8230 CIVIL TERM LEON G. RAMSEY, JR A/K/A LEON RAMSEY CUMBERLAND COUNTY TRACY RAMSEY F/K/A TRACY BOONE Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LEON G. RAMSEY, JR A/K/A LEON RAMSEY 112 E NORTH ST CARLISLE, PA 17013-2430 TRACY RAMSEY F/K/A TRACY BOONE 839 NORTH WEST STREET CARLISLE, PA 17013-1435 * *THIS FIltM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 839 NORTH WEST STREET, CARLISLE, PA 17013-1435 is scheduled to be sold at the Sheriff's Sale on 06/02/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $135,601.08 obtained by WELLS FARGO BANK, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone thhe sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may ca11215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution N0.09-8230 CIVIL TERM WELLS FARGO BANK, N.A. vs. LEON G. RAMSEY, JR A/K/A LEON RAMSEY TRACY RAMSEY F/K/A TRACY BOONE owner(s) of property situate in the BOROUGH OF CARLISLE, Cumberland County, Pennsylvania, being (Municipality) 839 NORTH WEST STREET, CARLISLE, PA 17013-1435 Parcel No. 06-19-1643-243. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $135,601.08 Phelan Hallman & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN Lot OR GROUND SITUATE IN THE BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE West BY North West Street; ON THE North BY Lot NO. 1, BLOCK 21 ON THE HEREINAFTER MENTIONED Plan OF Lots; ON THE East BY A 16 FOOT WIDE ALLEY; AND ON THE South BY PROPERTY NOR OR FORMERLY OF MRS. SUSAN MORRISON; CONTAINING 25 FEET IN FRONT ON SAID West North Street AND EXTENDING IN DEPTH AN EVEN WIDTH 190 FEET TO THE AFORESAID ALLEY, AND BEING Lot N0.2, BLOCK 21, IN A Flan OF Lots LAID OUT BY THE CARLISLE LAND AND IlVIPROVEMENT COMPANY, WHICH Plan IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN MISC. BOOK 11, PAGE 572. SAID Lot OF GROUND HAS THEREON ERECTED A TV~'O AND ONE-HALF STORY FRAME DWELLING HOUSE AND NECESSARY OUTBUILDINGS KNOWN AS 839 North West Street. TITLE TO SAID PREMISES IS VESTED IN Leon Ramsey and Tracy Ramsey, fka, Tracy Boone, h/w, by Deed from Tracy Boone, dated 04/15/2008, recorded 07/18/2008 in Instrument Number 200824513. PREMISES BEING: 839 NORTH WEST STREET, CARLISLE, PA 17013-1435 PARCEL NO.06-19-1643-243. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-8230 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., Plaintiff (s) From LEON G. RAMSEY, JR a/Wa LEON RAMSEY TRACY RAMSEY f/k/a TRACY BOONE (I) 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 $135,601.08 L.L.$.50 Interest from l/9/10 to Date of Sale ($22.60 per diem) -- $3,227.00 Atty's Comm % Due Prothy $2.00 Atty Paid $203.80 Other Costs Plaintiff Paid Date: 3/9/10 (Seal) Deputy REQUESTING PARTY: Name: COURTENAY R. DUNN, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 ~~ David D. Buell, P othonotary By: Supreme Court ID No. 206779 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA, Known and numbered as, 839 North West Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: Real Estate Coordinator ={~~ u, ~ ; .. ~~ The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~Ile~lahiot News NoW you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and alf 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 ernpowered 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: Wrk No. 2009-8230 Civll Term Wslb Fargo Bank, NA 04/16/10 :;A:ltustee ror ABFC Zoos-oPT3 Tnist, C-- 04/23/10 ABFC Asset-Backed C;ertlfleates, 04/30/10 Series ''~' 2006-0PT3!~/ vs. ~ ....... .... ............... -„ Leon G. Ramsey Tracy Ramsey Atty: Daniel G Schmleg a Sworn to~i subscribed before JYIe t 18 y~f May, 2010 A.D. By virtue of a Writ of Execution N0.09-8230 ~ CIVB,TERM ~~ ~J_•. WELLS FARGO BANK, N.A. ~~`` ~ t,~ f - ~ y ~ ~ _~ ~ -.~-___. °S' Nota Public ``~~''~~ LEON G. RAMSEY, JR A/K!A LEON ry RAMSEY TRACY RAM$EY F/K/A TRACY BOONE Owner(s) of property situate in the BOROUGH OF CARLISLE, Cumberland County, Pennsylvania, COMMbNYyEAL'1'M OF PENNSYLVANU\ being (Municipality) No17Ael Seel 839 NORTH WEST STREET, CARLISLE, PA Sherrie L. Klener, NggGa,y Public 17013-1435 Lower Paxton 71Mp,, DauphNi County Parcel No.06-19-1643-1A3. I"1Y ~mmission Expires Npv, 2(, 2011 (Acreage a street address) Member, PennsYlvanla Assodatlon of Notarlex Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $135,601.08 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: April 16, Apri123, and Apri130, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Writ No. 2009-8230 Civil Wells Fargo Bank, NA as Trustee for ABFC 2006-OPT3 Trust, ABFC Asset-Backed Certificates, Series 2006-OPT3 vs. Leon G. Ramsey Tracy Ramsey Atty: Daniel G. Schmieg By virtue of a Writ of Execution NO. 09-8230 CIVIL, WELLS FARGO BANK, N.A. vs. LEON G. RAMSEY, JR A/K/A LEON RAMSEY, TRACY RAM- SEY F/K/A TRACY BOONE, owners of property situate in the BOROUGH OF CARLISLE, Cumberland County, Pennsylvania, being 839 NORTH WEST STREET, CARLISLE, PA 17013-1435. Parcel No. 06-19-1643-243. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $135,601- .08. v ~.-.-- isa Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 30 day of Aril, 2010 ~.~~~~ ~. Notary ~ ~.~.~~~~ NOTARIAL SEAL DEBORAH A COLLINS Notary (Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 FILED-OFFICE OF THE PROTHONOTARY Phelan Hallman & SchmiegI!N 9 A? 9? It 6 1617 JFK Boulevard, Suite (T' One Penn Center Plaza CUMBERLAND COUNTY Philadelphia, PA 19103 PENNSYLVANIA 215-563-7000 Attorney For Plaintiff WELLS FARGO BANK, N.A. Plaintiff vs LEON G. RAMSEY, JR A/K/A LEON RAMSEY TRACY RAMSEY FJK/A TRACY BOONE Defendant Court of Common Pleas Civil Division CUMBERLAND County No. 09-8230 CIVIL TERM PRAECIPE TO THE PROTHONOTARY: ? Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ? Please mark the above referenced case Settled, Discontinued and Ended. ® Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ? Please ;rk t e in rem judgment Satisfied and the action Discontinued and Ended. Date: (2-- PHELAZfLL?CHMIEG, LLP Sheetal R. Shah-3ani, sq., I No.81760 Attorney for P f PHS # 221613 Q,,. 8 9,so Ind a d ck??ys?alYg Jl LI g4(9 Ci 4? g(ORRmo . . Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff vs LEON G. RAMSEY, JR A/K/A LEON RAMSEY TRACY RAMSEY F/K/A TRACY BOONE Defendant Attorney For Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 09-8230 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: LEON G. RAMSEY, JR A/K/A LEON RAMSEY TRACY RAMSEY F/K/A TRACY BOONE 839 NORTH WEST STREET CARLISLL , PA 17013-1435 Date: ( I7 Z BY: Sheetal R. Shah-Jani, sq., Id. o.81760 Attorney for PHS # 221613