HomeMy WebLinkAbout09-8508UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
L'?AM L. KAYES, ESQUIRE - ID #86408
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer =COURT OF COMMON PLEAS
Discount Company `_CIVIL DIVISION
961 Weigel Drive
Elmhurst, IL 60126 :Cumberland County
Plaintiff
V.
Carlos Ramos, II
Melanie S. Ramos (Mortgagor) °. NO . OQ - 8,508
365 Criswell Drive
Boiling Springs, PA 17007
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any
money claimed in the Complaint or for any other, claim or relief
requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF
YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
C
AVISO
Le han demandado a usted en la Corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la Corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso o
notificacion. Ademas, la Corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisioner de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
E'
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify
us in writing of a dispute within the 30 day period, we will obtain verification of the debt or
a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not
an admission of liability on your part. Also, upon your written request within the 30 day
period, we will provide you with the name and address of the original creditor if different from
the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
1. Plaintiff is the Corporation who the legal holder of the
Mortgage that is the subject of this Mortgage Foreclosure Action.
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum appearing on said mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 365 Criswell Drive
MUNICIPALITY/TOWNSHIP/BOROUGH: Monroe Township
COUNTY: Cumberland
DATE EXECUTED: 10/6/04
DATE RECORDED: 10/8/04 BOOK: 1883 PAGE: 4076
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized. by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
E
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
10/30/09:
Principal of debt due $141,988.06
Unpaid Interest at 8.730%
from 4/30/09 to 10/30/09
(the per diem interest accruing on
this debt is $33.96 and that sum
should be added each day after
10/30/09) 6,192.06
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Late Charges
(monthly late charge of $72.91
should be added in accordance
with the terms of the note
each month after 10/30/09) 119.58
Attorneys Fees (anticipated and actual
to 5% of principal) 7,099.40
TOTAL $156,004.10
7. The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be collected
in the event of a third party purchaser at Sheriff's Sale. If the
mortgage is reinstated prior to the sale, reasonable attorneyy's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A", and made part
hereof, and defendant (s) have failed to proceed within the time
E'
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE. the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $156,004.1.0 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
UDREN LAW OFFICES, P.C.
BY r Li _
Attorneys for Plain Jiff
MARK J. UDREN, ES IRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
f-
ALL THAT CERTAIN TRACT OF LAND LOCATED IN MONROE TOWNSHIP,
CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED
AND DESCRIBED AS FOLLOWS:
BEGINNING AT A RAILROAD MONUMENT IN THE NORTHERLY RIGHT-OF-
WAY LINE OF THE READING RAILWAY COMPANY AT CORNER OF LAND OF
ANNIE CRISWELL; THENCE BY LANDS OF ANNIE CRISWELL, NORTH 01
DEGREES 15 MINUTES WEST, A DISTANCE OF 389.9 FEET TO A NAIL IN THE
CENTER OF A PUBLIC ROAD; THENCE CONTINUING ACROSS SAID PUBLIC
ROAD ON THE SAME COURSE A DISTANCE OF 55.6 FEET, MORE OR LESS, TO A
POINT IN THE CENTER OF THE YELLOW BREECHES CREEK; THENCE BY THE
CENTER OF THE YELLOW BREECHES CREEK, NORTH 65 DEGREES 30
MINUTES WEST, A DISTANCE OF 75 FEET, MORE OR LESS, TO A POINT;
THENCE BY LANDS OF JOHN A. GOUSE, JR., ET UX, SOUTH 24 DEGREES 30
MINUTES WEST, A DISTANCE OF 53 FEET, MORE OR LESS; TO A POINT IN THE
CENTER OF THE AFORESAID PUBLIC ROAD; THENCE BY THE SAME AND
CONTINUING ACROSS THE SAID PUBLIC ROAD ON THE SAME COURSE A
DISTANCE OF 378.9 FEET TO A STAKE IN THE NORTHERLY RIGHT-OF-WAY
LINE OF THE READING RAILROAD COMPANY; THENCE BY THE NORTHERLY
RIGHT-OF-WAY LINE OF THE READING RAILROAD COMPANY, SOUTH 72
DEGREES EAST, A DISTANCE OF 272 FEET TO A RAILROAD MONUMENT, THE
PLACE OF BEGINNING.
CONTAINING- 1.70 ACRES, MORE OR LESS, AND HAVING A FRONTAGE ON THE
CENTER OF THE AFORESAID PUBLIC ROAD OF 100 FEET.
October 22, 2009
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
The HOMEOWNF,ROS MORTGAGE ASSISTANCE PROGRAM (HFMAPmay he able
to help to save your home. This Notice explains how the progrnm works.
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact an attorney in your area. The local bar association may be able
to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES
SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
0HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
EXHISIT A
Page 1 of 1
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER:
HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY HE ELIGIBLE FOR FiNANCiAi. ASSISTANCE
WHICH CAN SAVE. YOITR HOME, FROM FORECLOSURE AND
HELP YOU MAKE. FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE OACTO), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary
stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that
time you must arrange and attend a Oface-to-faceO meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
DHOW TO C1 TR E YOT TR MORTGAGE, DEEAT IT TD
RTGAGE TTP TO DATE-
CONSITMF.R CREDIT COITNSELING AGENCIES - If you meet with one of the consumer
credit counseling agencies listed at the end of this notice, the lender may NOT take action against
you for thirty (30) days after the date of this meeting. The names, addresses and elenhone numbers
of designated consumer credit counseling agencies for the n inl in which the =p?Cty is located
are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting.
Advise your lender immediate] of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE, - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature
of your default.) If you have tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies
listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing
Page 2 of 2
Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your
face- to-face meeting.
YOU MIDST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO
COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property
located at:
365 Criswell Drive
Boiling Springs PA 17007
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
_Monthly._Payments_of_$1458.17._for Maw 30?2009_throu$h_September 30, 2009.__= $7290.85
-Monthly. Late._Charr es._of...$ .91_for May 30.5.2009 through,-September 30,_2009___= $119.58
Other charges (explain/itemize):
TOTAL _AMOUNT _PAST DUE_ ............._........................._......._...._.._.. - - ---- - - --- ---......................................._._?._..
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): WA
HOW TO CURE THE. DEFAIII,T - You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS 57410.43- PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments must he made either by each, cashier's check, certified check or money order made payable
and cent to,
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter: (Do not use if not applicable-): WA
Page 3 of 3
IF YOIT DO NOT C TRF. THE. DEFAULT -- If you do not cure the default within THIRTY (30) DAYS
of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt- This
means that the entire outstanding balance of this debt will be considered due immediately and you may lose
the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
foreclose upon your mortgaged propcjU,
IF THE. MORTGAGE. IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff
to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency
before the lender begins legal proceedings against you, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against
you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed
$50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other
reasonable costs. If you cure the default within the THIRTY (0) DAY period, you will not he
required to pay aT nrney's fees-
OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without
your having reaffirmed it, then lender cannot pursue this remedy.
RIGHT TO CURE THF. DEFAULT PRIOR TO SHERIFF'S SAi.F, - If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the Tight to
cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale_ You may do sc N
payLg the total amount then spa. t due, ?c anI late nr other charges then due, reasonable attorney's fees and
costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as secn .ifed
in writing by the lender and hap erforming any nth .r r n iir .m its under the mortgage. Curing your
default in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
F.ARi LEST POSSIBLE. SHF.RiFF'S SAi.F. DATF. - It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from
the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment or action will be by contacting the lender.
FFFECT OF SHERIFF'S SAi.F. - You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASS TM"TON OF MORTGAGE. - You may not transfer your home to a buyer or transferee who will
assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs
are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
Page 4 of 4
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
Page 5 of 5
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF 'THIS
DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Page 6 of 6
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated: 10/15/2007 10:03:08 AM
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Captial Region
1514 Deny Street
Harrisburg, PA 17104
717.232.9757
Loveship, inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
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V E R I F I C A T I O N
The undersigned, hereby states that he/she is the attorney for
the Plaintiff, a corporation unless designated otherwise; that
he/she is authorized to take this Verification and does so because
of the exigencies regarding this matter, and because Plaintiff must
verify much of the information 'through agents, and because he/she
has personal knowledge of some of the facts averred in the
foregoing pleading; and that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge,
information and belief and the source of his information is public
records and reports of Plaintiff's agents. The undersigned
understands that this statement herein is made subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
UDREN LAW OFFICES,iP.C.
BY : x
Attorneys for Plad-iff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
0
THE I' Ur.:,.N!OTARY
2009D e -9 A! 10.39
fJ?v i JIN,Iy
r'L?a? z?i+ Jr.
$ga.oo Po ATrY
CI?? !'41543 I41lo3(v
R a3q 75q
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
F~iL~~'"~'~ ~„~.r~
'' ' ";'
~'= TNT f~~.;~:r,r.~~'~~,_+,~
2010 P~nY 13 P~~ ~~ t~O
Household Finance Consumer Discount Company
Plaintiff
v.
Carlos Ramos, II
Melanie S. Ramos (Mortgagor)
Defendant (s )
COURT OF COMMON PLEAS
ECIVIL DIVISION
€Cumberland County
ENO. 09-8508 Civil Term
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff, by its/his/her Attorney hereby verifies that:
1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is
attached hereto as Exhibit "A", was sent to every recorded lienholder and every
other interested party known as of the date of the filing of the Praecipe for the
Writ of Execution, on the date(s) appearing on the attached Certificates of
Mailing.
2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and
certified mail on the date appearing on the attached Return Receipt, which was
signed for by Defendant(s) on the date specified on the said Return Receipt.
Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B".
3. If a Return Receipt is not attached hereto, then service was by personal
service on the date specified on the attached Return of Service, attached hereto
as Exhibit "B".
4. If service was by Order of Court, then proof of compliance with said Order
is attached hereto as Exhibit "B".
All Notices were served within the time limits set forth by Pa Rule C.P. 3129.
This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
s.r.._...-------~---.
Dated: April 30, 2010
N~LAW OFFICE .C.
BY:
~ne_ys four Plaintiff
MARK J . ~J'DR N~, - ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Carlos Ramos, II
Melanie S. Ramos (Mortgaw~r)
Defendant(s)
Household Finance Consumer Discount
Company
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON
CIVIL DIVISION
Cumberland County
PLEAS
NO. 09-8508 Civil Term
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Carlos Ramos, II and Melanie S. Ramos (Mortgagor)
PROPERTY: 365 Criswell Drive, Boiling Springs, PA 17007
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the Cumberland County
Sheriffs Sale on June 2, 2010, at 10:00 A.M., in the Commissioners Hearing Room, 2ND
Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or
judgment on the property which will be extinguished by the sale. You may wish to
attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff
not later than 30 days after safe. Distribution will be made in accordance with the
schedule unless exceptions are filed thereto within 10 days after the filing of the
schedule.
v.
EXHIBIT A
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EX
IBI
/~- T
SHERIFF'S OFFICE OF CUMBERLAND COUNTY' ~~a`l'~
Ronny R Anderson
Sheriff
Jody S Srrllth ~~~,n~„ oi~ G~`tnr~6rr,~,~~a3
Chief Deputy "
j ;'{<
Edward L Schorpp
Solicitor c~r~. E ::~ -f-E :;..:N~Fr
Household Finance Consumer Discount Co
vs.
Carlos Ramos, III (et al.)
Case Number
2009-8508
SHERIFF'S RETURN OF SERVICE
04/06/2010 08:21 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10
at 2018 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 Carlos Ramos, III and Melanie S. Ramos, located at, 365
Criswell Drive, Boiling Springs, Cumberiand County, Pennsylvania according to law.
04/06/2010 08:21 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10
at 2018 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: Carlos Ramos, III, by making known unto,
Melanie S. Ramos, spouse, at, 365 Criswell Drive, Boiling Springs, Cumberland County, Pennsylvania its
contents and at the same time handing to her personally the said true and correct copy of the same.
04/06/2010 08:21 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10
at 2018 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: Melanie S. Ramos, by making known unto,
Melanie S. Ramos, personally, at, 365 Criswell Drive, Boiling Springs, Cumberland County, Pennsylvania
its contents and at the same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $908.92 SO ANSWERS,
..~..
April 26, 2010 RON R ANDERSON, SHERIFF
~.IH~~il`~- ~
;c; CountySuite Shenff. Teiees^ft. Inc. ~ c' ~ ~ ~/ r ~ ~ ~ (,~~
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson r ~` '..
Sheriff ` ~. _ ~', ...: -~- , -„r
~~~~ttin of ~n~nbrrLr~G
Jody S Smith ~
Chief Deputy _ ~ ~ ; ~ ~ ~ _- . f' " `'
j ~r'_ I~IY1 /D : $D
Richard W Stewart Lv,
Solicitor ~,r., ~,~Fs~G _..w~~~ .._ ~;';"`(
Household Finance Consumer Discount Co Case Number
vs.
Carlos Ramos, III (et al.) 2009-8508
SHERIFF'S RETURN OF SERVICE
04/06/2010 08:21 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10
at 2018 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 Carlos Ramos, III and Melanie S. Ramos, located at, 365
Criswell Drive, Boiling Springs, Cumberland County, Pennsylvania according to law.
04/06/2010 08:21 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10
at 2018 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: Carlos Ramos, III, by making known unto,
Melanie S. Ramos, spouse, at, 365 Criswell Drive, Boiling Springs, Cumberland County, Pennsylvania its
contents and at the same time handing to her personally the said true and correct copy of the same.
04/06/2010 08:21 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10
at 2018 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: Melanie S. Ramos, by making known unto,
Melanie S. Ramos, personally, at, 365 Criswell Drive, Boiling Springs, Cumberland County, Pennsylvania
its contents and at the same time handing to her personally the said true and correct copy of the same.
06/03/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice
had been given according to law, he exposed the within described premises at public venue or outcry at
the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 2, 2010 at 10:00 o'clock A.M. He
sold the same for the sum of $1.00 to Attorney Adam L. Kayes, on behalf of Household Finance
Consumer Discount Company, 961 Weigel Drive, Elmhurst, IL 60126, being the buyer in this execution,
paid to Sheriff Ronny R. Anderson, the sum of $ 930.82
SHERIFF COST: $930.82 SO ANSWERS,
June 30, 2010 RON R ANDERSON, SHERIFF
. so u~~.
~'~ 7~o~G
,~ a~Sa90
!ci Count~Suite Shenft. Teleaso`t, ins.
' iTDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
r ~ MARK J. UDREN, ESQUIRE - ID #04302
STUART WINIQEG, ESQUIRE - ID #45362
LORR.AINE~~O~fLE,• ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer :COURT OF COMMON PLEAS
Discount Company :CIVIL DIVISION
Plaintiff :Cumberland County
v.
;MORTGAGE FORECLOSURE
Carlos Ramos, II €NO. 09-8508 Civil Term
Melanie S. Ramos (Mortgagor)
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Household Finance Consumer Discount Company, Plaintiff in the
above action, by its attorney, Mark J. Udren, ESQ., sets forth as
of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at:
365 Criswell Drive, Boiling Springs, PA 17007
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Carlos Ramos, II
365 Criswell Drive
Boiling Springs, PA 17007
Melanie S. Ramos (Mortgagor)
365 Criswell Drive
Boiling Springs, PA 17007
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name Address
Cumberland County
Adult Probation
1 Courthouse Sq.
Carlisle, PA 17013
Monroe Township
Municipal Authority
Colorado Capital
Investments, Inc.
1220 Boiling Springs Rd.
Mechanicsburg, PA 17055
409 North Main
Weatherford, TX 76086
A
Midland Funding LLC
i
Arrow Financial
Services, LLC
c/o Apothaker & Assoc. P.C.
520 Fellowship Road, C306
Mt. Laurel, NJ 08054
c/o Apothaker & Assoc. P.C.
520 Fellowship Road, C306
Mt. Laurel, NJ 08054
4. Name and address of the last recorded holder of every mortgage
of record:
Name Address
Household Finance 961 Weigel Drive
Consumer Discount Company Elmhurst, IL 60126
5, Name and address of every other person who has any record lien
on the property:
Name Address
None
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
Name Address
Real Estate Tax Dept
1 Courthouse Sq.,
Carlisle, PA 17013
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
13 N. Hanover St.
Carlisle, PA 17013
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale:
Name Address
Tenants/Occupants
365 Criswell Drive
Boiling Springs, PA 17007
I verify that the statements made in this affidavit are true and
~ correct to the best of my personal knowledge or information and
belief. I understand that false statements herein are made
subject to, the 'penalties of 18 Pa.C.S. sec. 4904 relating to
unsworn falsification to authorities.
DATED: January 15, 2010
UDREN LAW OFFICES;~P.C.
C B Y ~,
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
'6~DD`EN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
1KARK J. LTDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORR.AINE~DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CEANDRA M. ARKEMA, ESQUIRE - ID #203437
2.OUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
~nT00DCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Household Finance Consumer ;COURT OF COMMON PLEAS
Discount Company :CIVIL DIVISION
Plaintiff :Cumberland County
v.
:MORTGAGE FORECLOSURE
Carlos Ramos, II NO. 09-8508 Civil Term
Melanie S. Ramos (Mortgagor)
Defendant (s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
T0: Carlos Ramos, II
365 Criswell Drive
Boiling Springs, PA 17007
Your house (real estate) at 365 Criswell Drive, Boiling Springs,
PA 17007 is scheduled to be sold at the Sheriff's Sale on June 2,
2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor,
Courthouse, Carlisle, PA, to enforce the court judgment of
$158,837.75, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
• YO~T MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. .If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. You may find out the price bid by calling 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
ALL THAT CERTAIN TRACT OF LAND LOCATED IN MONROE TOWNSHIP,
CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED
AND DESCRIBED AS FOLLOWS:
BEGINNING AT A RAILROAD MONUMENT IN THE NORTHERLY RIGHT-OFWAY
ZINE OF THE READING RAILWAY COMPANY AT CORNER OF LAND OF ANNIE
CRISWELL; THENCE BY LANDS OF ANNIE CRISWELL, NORTH Ol DEGREES 15
MINUTES WEST, A DISTANCE OF 389.9 FEET TO A NAIL IN THE CENTER OF
A PUBLIC ROAD; THENCE CONTINUING ACROSS SAID PUBLIC ROAD ON THE
SAME COURSE A DISTANCE OF 55.6 FEET, MORE OR LESS, TO A POINT IN
THE CENTER OF THE YELLOW BREECHES CREEK; THENCE BY THE CENTER OF
THE YELLOW BREECHES CREEK, NORTH 65 DEGREES 30 MINUTES WEST, A
DISTANCE OF 75 FEET, MORE OR LESS, TO A POINT; THENCE BY LANDS OF
JOHN A. GOUSE, JR., ET UX, SOUTH 24 DEGREES 30 MINUTES WEST, A
DISTANCE OF 53 FEET, MORE OR LESS, TO A POINT IN THE CENTER OF
THE AFORESAID PUBLIC ROAD; THENCE BY THE SAME AND CONTINUING
ACROSS THE SAID PUBLIC ROAD ON THE SAME COURSE A DISTANCE OF
378.9 FEET TO A STAKE IN THE NORTHERLY RIGHT-OF-WAY LINE OF THE
READING RAILROAD COMPANY; THENCE BY THE NORTHERLY RIGHT-OF-WAY
DINE OF THE READING RAILROAD COMPANY, SOUTH 72 DEGREES EAST, A
DISTANCE OF 272 FEET TO A RAILROAD MONUMENT, THE PLACE OF
BEGINNING.
CONTAINING 1.70 ACRES, MORE OR LESS, AND HAVING A FRONTAGE ON THE
CENTER OF THE AFORESAID PUBLIC ROAD OF 100 FEET.
BEING KNOWN AS: 365 Criswell Drive
Boiling Springs, PA 17007
PROPERTY ID NO.: 22-30-2664-013
TITLE TO SAID PREMISES IS VESTED IN CARLOS RAMOS II BY DEED FROM
CARLOS RAMOS II AND CHRISTINE RAMOS, HIS WIFE DATED 6/18/97
RECORDED 6/18/97 IN DEED BOOK 159 PAGE 615.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF'CUMBERLAND)
NO 09-8508 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY, Plaintiff (s)
From CARLOS RAMOS, II and MELANIE S. RAMOS
(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 $158,837.75
L.L. $.50
Interest from 1/16/10 to 6/2/10 ongoing per diem of $33.96 to actual date of sale including if sale is
held at a later date -- $4,686.48
Atty's Comm
Due Prothy $2.00
Atty Paid $181.90 Other Costs
Plaintiff Paid
Irate: i/ISl10
L
(Seal)
By:
D. Buell, Prothonotary
Deputy
REQUESTING PARTY:
Name: ALAN M. MINATO, ESQUIRE
Address: UDREN LAW OFFICES, PC
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Te 1 ephone: 856-669-5400
Supreme Court ID No. 75860
On March 22, 2010 the Sheriff levied upon the
defendant's interest in the real property situated in
Monroe Township, Cumberland County, PA,
Known and numbered as, 365 Criswell Drive, Boiling Springs,
more fully described on Exhibit "A" filed with this writ and
by this reference incorporated herein.
Date: March 22, 2010
By:
____.~
Real Estate Coordinator
S ~, :~ d O Z Ply f Cl~~?
~:;
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.
,--
L' a Marie Coyne, itor
SWO TO AND SUBSCRIBED before me this
30 da of Aril 2010
Notary
NOTARIAL SEAL
DEBORAH A COLLiNS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
Writ 110. 9009-8601 Citil
Household Finance Consumer
Discount Co.
vs.
Carlos Ramos, III
Melanie S. Ramos
Atty: Adam L. Kayes
ALL THAT CERTAIN tract of land
located in Pennsylvania, more par-
ticularly bounded and described as
follows:
BEGINNING at a railroad monu-
ment in the northerly right-ofway
line of the Reading Railway Company
at corner of land of Annie Criswell;
thence by lands of Annie Criswell,
North O1 degrees 15 minutes West,
a distance of 389.9 feet to a nail in
the center of a public road; thence
continuing across said public road on
the same course a distance of 55.6
feet, more or less, to a point in the
center of the Yellow Breeches Creek;
thence by the center of the Yellow
Breeches Creek, North 65 degrees
30 minutes West, a distance of 75
feet, more or less, to a point; thence
by lands of John A. Gouse, Jr., et
ux, South 24 degrees 30 minutes
West, a distance of 53 feet, more or
less, to a point in the center of the
aforesaid public road; thence by the
same and continuing across the said
public road on the same course a
distance of 378.9 feet to a stake in
the northerly right-of-way line of the
Reading Railroad Company; thence
by the northerly right-of-way line of
the reading railroad company, south
72 degrees east, a distance of 272 feet
to a railroad monument, the place of
BEGINNING.
CONTAINING 1.70 acres, more
or leas, and having a frontage on the
center of the aforesaid public road
of 100 feet.
BEING KNOWN AS: 365 Criswell
Drive, Boiling Springs, PA 17007.
PROPERTY ID NO.: 22-30-2664-
013.
TITLE TO SAID PREMISES IS
VESTED IN Carlos Ramos II by deed
from Carlos Ramos II and Christine
Ramos, his wife dated 6/ 18/97 re-
corded 6f1$f97 in Deed Book 159
Page 615.
..The Patriot-News Co.
2020 Technology Pkwy
Suite 300
Mechanicsburg, PAj,17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
c'~e~lahiot News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
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
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:
04116/10
! 04/23/10
~ ~ ~ 04130/10
Sworn to ~,t;ubscribed before me )his 1> f May, 2010 A.D.
blic
COMMONWEALTH OIL P~NNSYLNANIA
Nobrlal SNI
Sherrie L. Krinlir, Notary Publk
Lower Paxton TWp., Dauphin County
My Commi~lon Expin9s Nov. 26, 2011
Member, PennsvNanla Association of Notaries
~~~~1~M
~rtt
V~ .
Carl4r Iq ,
~,. A~~~n L 1~s
ALL Tf3AT Cfi1tTAIN TRACT OP LAND
LOCATfU~,~T`I~QNRUB ,~
EA.A~S4~A~ ~~
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BF¢IIdNItJG AT;4RAII:RpgD MONr1MRNT
LIt7B OJ? TES ~DE+iQ , .RAIi.WAY
COMPANY Kf CE~It OF ,LAND pP
nirmcwspw~rrtL,.iHO1S I3
~aA" OF389:9FF~T
TO A NAD, IN 7Nq OP A PUBLH~
$i '! C,~iT~R OF.
cacrnR, r~nc~x ~ "DEQR~R 30 M1NlffES:.
wesT,A ~ ~?7i J; t oR
r,.~ts, mo ~ fir; aY`L~s
OF7(~i1V ~. L70ITSE; )R., Pf UJC. SOt7JxJ ~i
'DEG1l~S 30 Y~ill'fB3 WEST, A Dd91'At±i~B.
OF S3 FSET; MOit& OR iFBS, TO,A,pp~7T
IN TtiB CENTBit OF, TJ~. APO1tESAID
PU$LIC ROAD TI$~ AY ~'~A~r
ArtD coNTn1~ ACRES ,~ ,
etmuC RoAn o1~ s,e
DJSTANCfi OF 37$,~,FES[ 3,~ A~1'A?~'JN
THB NORTFR~,Y.R~T-0E+iVilY',LII+iB .
OF 1tiE R$(x RAIL~A4p may;
TH~+NCE BY T1~6 Y f,QF•
wAY.J~ c3F,~~ RAII~iDAr~
CO1viFAAIY, SOC)'!H 72 DECiR~ES EAST A
CEN'S'ER OP APSAm PUBLIC
ROAN OF lU9J:
ECG KN~V'NA$; 365 C~aaKJ! Drt~e,
Spt~r,_PA.Yi007 _ ;
~JCOPERTY ID NO.: 22»3U~~6bA~Q~3
i'J1Z.E 1`QSA~O PRF,lHSES.I3 VBST~.?'~N
ItAtiM#6 II ~ RJb1fQS; ~4
RIP Iff111!'i N,#M N
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which HOUSEHOLD FINANCE C D C is the grantee the same having been sold
to said grantee on the 2ND day of JUNE A.D., 2010, under and by virtue of a writ Execution issued on
the 15TH day of JAN, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term,
2009 Number 8508, at the suit of HOUSEHOLD FINANCE C D C against CARLOS RAMOS II &
MELANIE S is duly recorded as Instrument Number 201018326.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this g
day of
of Deeds
Recorder o1 Deede, ~lanbe-~d (~-~ CerAeM, !y1
Mp Conmission E~ires the Hr:t Ukx~dq-dJen 2014