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HomeMy WebLinkAbout10-4748. ,.? T};r T,ARY 2010 J, Ili L 1 9 Pi"i ? 4 GJ?s?? , , wTY McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC 10790 Rancho Bernardo Road San Diego, California 92127 V. Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number `a , 4/ 7 y P-c M' Jan CIVIL ACTIONIMORTGAGE FORECLOSURE M.,06 P't al, d# lIV613 A-A ?y Sy7 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le han demandado a usted en. la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar 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 defiende, 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. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Chase Home Finance, LLC, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Keith R. Ramsey, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his last-known address is 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. 3. On April 2, 2004, Keith R. Ramsey made, executed and delivered a mortgage upon the premises hereinafter described to ERA Mortgage which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1860, Page 1467. 4. On December 4, 2007, the aforesaid mortgage was thereafter assigned by ERA Mortgage to J.P. Morgan Chase Bank, NA, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assignment of Instrument 200745007. 5. The aforesaid mortgage was thereafter assigned by J.P. Morgan Chase Bank, NA to Chase Home Finance, LLC, Plaintiff herein, by Assignment of Mortgage, which will be duly recorded in the Office of the Recorder of Cumberland County. 6. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. 7. The mortgage is in default because monthly payments of principal and interest upon said mortgage due April 1, 2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following amounts are due on the mortgage: Principal Balance $ 117,091.91 Interest through July 7, 2010 $ 9,322.94 (Plus $18.85 per diem thereafter) Attorney's Fee $ 1,300.00 Late Charges $ 852.02 Corporate Advance $ 150.50 Escrow Advance $ 2,960.75 GRAND TOTAL $ 131,678.12 9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands an in rem Judgment against the Defendant in the sum of $131,678.12, together with interest at the rate of $18.85 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY,P.C. BY: MAZ- Attorneys for Vaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiff, who is not available to sign this, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG AND CONWAY,P.C. BY: Attorneys for aintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE search - 2010-7459.ecm COMMITMENT SCHEDULE C Exhiblot A File Number: OR31410BL ALL THAT CERTAIN piece or parcel of land, situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at the Southwest corner of Hampden Avenue and Courtland Street on the hereinafter mentioned plan of lots; thence South 87 degrees 21 minutes West along the southern side of Courtland Street 80 feet to a point at the division lines of lots numbered 159 and 160; thence South 1 degree 52 minutes East along said division line 86.51 feet to a point at the division line of Lots numbered 158 and 159; thence South 79 degrees 38 minutes East along said division line a distance of 83.31 feet to a point on the division line a distance of 83.31 feet to a point on the western side of Hampden Avenue; thence North 2 degrees 39 minutes West along said Hampden Avenue, 105.26 feet to a point the place of beginning. HAV1G thereon erected a single one story brick ranch dwelling, said premises being known and numbered as 106 Hampden Avenue, Camp Hill, Pennsylvania. BEING Lot # 159 on the general plan of Section 2 and 3 of Clearview Farms recorded in and for County of Cumberland in Plan Book 9 page 6. Parcel No.: 10-21-0279-142 s Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717.240.6397 Plaintiffs: Court Number: Chase Home Finance, LLC Expiration Date: of Action: Defendants: Keith R. Ramsey Service Upon: Keith R. Ramsey Address for Service: 106 Hampden Avenue, Camp Hill, Pennsylvania 17011 Alternate Address for Service: Type of Service: XAdult in Charge ? Personal ? Deputize ? Certified Mail ? Posting (copy of court order required) Special Service Instructions: SPECIAL INSTRUCTIONS If service is made upon an "ADULT IN CHARGE', please abtain relationship to defendant or confitmtion that 9efendant still resides at the property. or * *1f service is to be made by deputizOl-uPant Wdefendant does not reside at property, please serve county _ ch Filing Attorney's Information Name: Terrence J. McCabe, Esquire, Marc S. Weisberg, Esquire, Edward D. Conway, Esquire, Margaret Gairo, Esquire Address: 123 South Broad Street, # 2080 Philadelphia, PA 19109 Telephone: (215) 790-1010 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Plaintiff V. Keith R. Ramsey Defendant 71 Attorneys for Plaintiff 2: 13 E ?;I110- -.lJ l n : . Cumberland County Court of Common Pleas Number 10-4748 CIVIL MOTION TO ALLOW SERVICE ON THE DEFENDANTS PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 Plaintiff attempted to personally serve a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Keith R. Ramsey, at his/her last-known address and mortgaged property of 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. The process server was not able to serve the Defendant because there was no response after multiple attempts. A true and correct copy of the Return of Service indicating the same is attached hereto., made a part hereof as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has conducted a good faith investigation to determine the current whereabouts of Defendant and the attached Affidavit sets forth in detail the nature and extent of the investigation. See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B". 3. As a result of the investigation, a special Order of Court is required permitting service by regular and certified mail at the Defendant's last known address and by posting a copy of the original process on the mortgaged premises. 4. No judge has ruled upon any other issue in this matter or in any related matter. 5. No attorney has entered an appearance in this matter on behalf of Defendant and, therefore, no concurrence of opposing counsel was sought with regard to the instant motion. 6. If service cannot be made on the Defendant, Keith R. Ramsey, the Plaintiff will be prejudiced. WHEREFORE, Plaintiff prays this Honorable Courtgrant an Order allowing the Plaintiffto serve the Complaint in Mortgage Foreclosure.. and all other subsequent pleadings that require personal service, and the Notice of Sheriff's Sale upon the Defendant, Keith R. Ramsey, by regular mail; certified mail, return receipt requested; and by posting at the last-known address of Defendant and the mortgaged premises known in this herein action as 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. TERRENC J. McCABE, ESQUIRE MARC S. EISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WE:ISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Cumberland County Court of Common Pleas Plaintiff V. Keith R. Ramsey Defendant Number 10-4748 CIVIL MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. TERRE`NC J. McCABE, ESQUIRE MARC S. EISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Plaintiff V. Keith R. Ramsey Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 10-4748 CIVIL CERTIFICATION OF SERVICE C ;? Esquire, attorney for the Plaintiff, hereby certify that I served a true and correct copy of the foregoing Motion for Alternative Service, by United States Mail, first class, postage prepaid, on the 9th day of September, 2010, upon the following: Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff TERRENC . G, McCABE, ESQUIRE MARC S. ISBERESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. TE RENC J. McCABE, ESQUIRE MARC S. EISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?p?tiula pt Kut? ?rt'I rk' R? c-H Chase Home Finance LLC Case Number vs. Keith R. Ramsey 2010-4748 SHERIFF'S RETURN OF SERVICE 08/18/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on August 18, 2010 at 0850 hours, he was unable to serve a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Keith R. Ramsey. After several attempts the Complaint in Mortgage Foreclosure has expired and the current occupant of 106 Hampden Avenue, Camp Hill, PA 17011 would not answer the door. SHERIFF COST: $68.50 SO ANSWERS; August 18, 2010 RbNl`V R ANDERSON, SHERIFF Exhibllt A ,: (" urm*9Suae;>h'r 1'f 1'e ,,oa;r't u-.c ?'qn 4-S? li'i ';T Attorney Outsourcing Support Services, Inc. Suite 2040 123 S. Broad Street Philadelphia, PA 19109 (215) 790-5964 FAX (215) 320-5779 AFFIDAVIT OF GOOD FAITH INVESTIGATION SUBJECT OF INVESTIGATION: Keith R. Ramsey CLIENT: FILE #: 49752 MATTER # 116-6033 ROSS FILE #: 10-5366 SUBJECT'S LAST KNOWN ADDRESS: 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. Oscar Dungan- , being duly sworn according to law, depose and say that Attorney Outsourcing Support Services, Inc. completed a good faith investigation into the whereabouts of the above named subject and the extent of the investigation and the results are as follows: INQUIRY OF POSTAL AUTHORITY: Postal Authority did not respond to several written requests. 2. INQUIRY OF LOCAL TELEPHONE COMPANY: A. DIRECTORY ASSISTANCE AND INTERNET SEARCH: The subject has a listed phone number of (717) 695-2226 for the above stated last known address. Exhibit B Page Two, 10-:5366 Investigation of Keith R. Ramsey continued: (Subject name) 3. INTERNET SEARCH: Search shows the subject has no change of address. 4. INQUIRY OF DEPARTMENT OF MOTOR VEHICLES: I was unable to verify current drivers license information for the subject. 5. DEATH RECORDS: Social Security has no death record for the subject. 6. LOCAL TAX RECORD INQUIRY: Tax bill is mailed to property address: 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. 7. INQUIRY OF COUNTY VOTER REGISTRATION: The subject is registered at property address: 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. 8. INQUIRY OF NEIGHBORS: Esther S Boltz 101 Hampden Ave Camp Hill, PA 17011-4031 (717) 761-3674 : Adult Female stated that she don't know the subject. Donna L Schorr 103 Hampden Ave Camp Hill, PA 17011-4031 (717) 730-9565 : Left a voice mail. The information set forth in this Affidavit of G od Faith Investigation is true and correct to the best of my knowledg, nrmation an?belief. BY: f 2vlj/ Signature k ~; NAME: Oscar Dungan Print Notary Public: Sworn to and subscribed before me this ',fCi day of r,?,>,.CV TITLE: Location Specialist I ATE: 9 ` ! DIla CHASE HOME FINANCE, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW KEITH R. RAMSEY, Defendant NO. 10-4748 CIVIL TERM IN RE: MOTION TO ALLOW SERVICE ON THE DEFENDANT PURSUANT TO PA. RULE OF CIVIL PROCEDURE 430 ORDER OF COURT AND NOW, this 14th day of September, 2010, upon consideration of the Motion To Allow Service on the Defendant Pursuant to Pa. Rule of Civil Procedure 430, it is ordered and directed that service of the complaint in this case upon Keith R. Ramsey may be made (1) by regular and certified mail at 106 Hampden Avenue, Camp Hill, Pennsylvania 17011, service to be deemed complete upon mailing, (2) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, and (3) by posting of the said property. FOLLOWING SERVICE of original process in the manner prescribed above, service of subsequent papers may be made (1) by regular mail to Defendant's said last known address and (2) by posting of the said property. BY THE COURT, J" Wesley tiler, Jr., C) ...? ; r MT 8 J . -,--Terrence J. McCabe, Esq. Marc S. Weisberg, Esq. Edward D. Conway, Esq. Margaret Gairo, Esq. 123 South Broad Street Suite 20880 Philadelphia, PA 19109 Attorney for Plaintiff : rc fY Q/fs/`o ~'1~~'~-~~ ICE ~~ T~iE t'r~ ~NO~O7ARY Cl~M~ERLAt~O CGUP~~'Y P~~PI5YLO~ANIA McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIItE - ID # 28009 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (2151790-1010 Chase Home Finance, LLC Plaintiff v. Keith R. Ramsey Defendant TO THE PROTHONOTARY: Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 10-4748 CIVIL PRAECII'E TO REINSTATE COMPLAINT Kindly reinstate the Complaint in Mortgage Foreclosure in the ab - ptioned after. TERREN J. BE, ESQUIRE MARC S. ERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE Attorneys for Plaintiff #lo.oo Qp ~-rr~ ~~ la~ho5 ~~' aye X95 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~z~~~t' of ~uuatrrp~~~~~ Jody S Smith Chief Deputy ~~` ,~ 1 .'r-, Richard W Stewart Solicitor ~~fr~~ ~'~ ~~.~ `-"~~'~~ Chase Home Finance LLC Case Number vs. 2010-4748 Keith R. Ramsey SHERIFF'S RETURN OF SERVICE 09/27/2010 05:27 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 27, 2010 at 1727 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Keith R. Ramsey, pursuant to order of court by posting the premises located at 106 Hampden Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 with a true and correct copy according to law. -~ NOAH CLINE, DEPUTY SHERIFF COST: $47.50 September 28, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF c. c~ ~ u~s ~ N ~o ~ ~ c~ "=~ "'o ~~ ~-r, ca-ra =~ r3 ~. c~ e :.~ c ~ c ~ P~ ~ ~ r ~fi ~, rv z„ ~ (C) Gou!tiySuite Shentf, TeIeoSOfP. Ii1G- McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Plaintiff v Keith R. Ramsey Defendant Attorneys for Plaintrf Gn = +c _ . CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-4748 CIVIL ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal Interest from 07/08/10 to 03/08/11 Total $ 131,678.12 $ 4,599.40 $ 136,277.52 c TERRE CE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff au* *l4.oo'pd at1 u? aW Gt mai gad Iv AND NOW, this %5 day of T"OJ&k , 2011, Judgment is entered in favor of Plaintiff, Chase Home Finance, LLC, and against Defendant, Keith R. Ramsey, and damages are assessed in the amount of $ 136,277.52, plus interest and costs. BY TH ROTHONOTARY: McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Plaintiff V. Keith R. Ramsey Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-4748 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendant, Keith R. Ramsey, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant, Keith R. Ramsey, is over eighteen (18) years of age, and reside as follows: Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 SWORN AND SUE OFF?Lt le) NOTARY PUBLIC :OMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Barbara J. Moyer-Notary Public city of Philadelphia, Philadelphia County MY COMMISSION EXPIRES JAN. 12, 2014 _ntalz_ 7jtele? TERRE E J. MCCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Plaintiff V. Keith R. Ramsey Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-4748 CIVIL AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing address of the Defendant is: Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 SWORN AND SUBS BEF E THIS OF 01 NO ARY PUBLIC :OMM13NWEAL-TH [IF PENN$YL_VANIA N13TARIAL SEAL Barbara J. Moyer- Notary Public City of Philadelphia, Philadelphia County MY COMMISSION EXPIRES JAN. 12, 2014 C TERRENFE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Plaintiff V. Keith R. Ramsey Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-4748 CIVIL CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendant that judgment would be entered against him/her within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEF E THIS Y OF W.G2011 Y PUBLI NpTARIAL SEAL ? Moyer -Notary Public Barbara Chy ?{ Phltadelphia, PRESJ AN.112, 014 I ? COMMISSION EXP Ao'v- TERRE)(CE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. TERRE E J. McCABE, ESQUIRE MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff L) 152 OFFICE OF THE PROTHONOTARY ( D COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary November 4, 2010 To: Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 Chase Home Finance, LLC Cumberland County vs. Court of Common Pleas Keith R. Ramsey Number 10-4748 CIVIL NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT 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 TI IE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU W ITHOUT 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'TOOR 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 TOPRQVIDE YOU WITH INFORMATION A90UTAGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE: PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800)990-9108 NOTIFICACION IMPORTANTE USTED SE FNCUENTRA EN ESTADO DE REBELDIA POP NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ES7'E TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DF.NTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL, PODRA, SIN NECESIDAD DE COMPARECER LISTED FN CORTE U OIR PREUBA ALGUNA, DICPAR SENTENCIA EN SU CONTRA Y USTED PODKIA PERDER B19NES IJ OTROS DFRF.CHOS IMPORTANTES. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO THINE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INPORMACIoN ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, FSTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMATON ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LAS SERVICIOS LEOALES A PERSONAS ELEGBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. crI (County Bar Association Iffy Avenue le, Pennsylvania 17013 990-9108 BY: Attorneys fo a of TERRENCE J. McCABE, QUI MARC S. WEISBERG, ES EDWARD D. CONWAY, E I1 MARGARET GAIRO, ESQUIRE mmo WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-4748 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE, LLC Plaintiff (s) From KEITH R. RAMSEY (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 $136,277.52 L.L.$.50 Interest from 3/09/11 - - $4,099.20 at $22.40 Atty's Comm % Atty Paid $258.50 Plaintiff Paid Date: 3/15/11 Due Prothy $2.00 Other Costs (Seal) REQUESTING PARTY: Name: MARGARET GAIRO, ESQUIRE Address: MCCABE WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Deputy Supreme Court ID No. 34419 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Chase Home Finance, LLC V. Keith R. Ramsey FILE NO.: 10-4748 CIVIL Civil Term n AMOUNT DUE: $136,277.52 3 _ !7D INTEREST: from 03/09/11 $4,099.20 at $22.40 cn -<> --- cn ATTY'S COMM.: .C c7 x °v COSTS: p TO THE PROTHONOTARY OF SAID COURT: ` The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. cr rya ?.-` C)_ .t := C) 5E PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 106 Hampden Avenue, Camp Hill, Pennsylvania 17011 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: March 9, 2011 S?4-co FLA all IF O'g.So (',6F r! 47-60 01a.o0 r? ?d. oo.?„ 1q.oo d. so urr Is i:5-?-.50 ?d a?'f Signature: Print NameACCAV,C1EISBERG AND CONWAY Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. . SO LL asU ta Oo \'UN? C? ?e J-AU'J V McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 i ' E... G ? ? t• i" i ? G.. Ph ? t Attorne s ff CUMBERLAP?I? W o PENNSYLVANIA Chase Home Finance, LLC CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 10-4748 CIVIL Keith R. Ramsey Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 106 Hampden Avenue, Camp Hill, Pennsylvania 17011, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Keith Ramsey 106 Hampden Ave Camp Hill, Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Cumberland County Adult Probation William H. Paul, DDS Address 1 Courthouse Square Carlisle, Pennsylvania 17013 c/o M.L. Van Eck, Esq. P.O. Box 6662 Harrisburg, Pennsylvania 17112 I 4. 5. 6. Name and address of the last recorded holder of every mortgage of record: Name Address ERA Mortgage 3000 Leadenhall Road Mount Laurel, New Jersey 08504 Name and address of every other person who has any record lien on the property: Name Address None Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 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 Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 106 Hampden Avenue Camp Hill, Pennsylvania 17011 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales United States of America Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Name and address of Attorney of record: Name None Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address 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. Section 4904 relating to unsworn falsification to authorities. March 8, 2011 DATE TERRE E J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff IT McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW Chase Home Finance, LLC V. Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Keith R. Ramsey Number 10-4748 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 is r1.) r s C rri O U) ?. Ul ?- .. r > Your house (real estate) at 106 Hampden Avenue, Camp Hill, Pennsylvania 17011 is scheduled to be sold at Sheriffs Sale on September 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $136,277.52 obtained by Chase Home Finance, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to Chase Home Finance, LLC the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 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. 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 the following notice 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 I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 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 a 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 f Keith R. Ramsey Defendant '.g 3 I 'f??' T 1 ;A IG `; 2 "'. "MERLAND COUNT`?ttorney for Plaintiff 'ENNSYL`1A"dM CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-4748 CIVIL AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 21 st day of July, McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Plaintiff v. 2011, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSC I QOMMONW LTH OF PENNSYLVANir NOTARIAL SEAL B&rbara J. Moyer- Notary Public Chy of Philadelphia, Philadelphia County MY COMMISSION EXPIRES JAN. 12, 2014 BEFOR ETHI DAY OF 12011 NOTARY PUBLIC eli PFF,V u1SONO If" R' McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff By: )?- TERR NCE McCABE, ESQUIRE - ID # 16496 MARC S. W SBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 V McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Plaintiff V. Keith R. Ramsey Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-4748 CIVIL AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 106 Hampden Avenue, Camp Hill, Pennsylvania 17011, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Keith Ramsey 106 Hampden Ave Camp Hill, Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Cumberland County Adult Probation 1 Courthouse Square Carlisle, Pennsylvania 17013 V William H. Paul, DDS c/o M.L. Van Eck, Esq. P.O. Box 6662 Harrisburg, Pennsylvania 17112 4. Name and address of the last recorded holder of every mortgage of record: Name Address ERA Mortgage 3000 Leadenhall Road Mount Laurel, New Jersey 08504 5. Name and address of every other person who has any record lien on the property: Name Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 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 Tenants/Occupants Address 106 Hampden Avenue Camp Hill, Pennsylvania 17011 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 1 10 North 8" Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o Arty General of the United States United States of America c/o Atty General of the United States Name and address of Attorney of record Name U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address 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. Section 4904 relating to unsworn falsification to authorities. McCABE, WEISBERG & CONWAY, P.C. July 21, 2011 Attorneys for Plaintiff DATE By: TERRENCE . McCABE, ESQUIRE MARC S. W ISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD 1). CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J.COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Plaintiff V. Keith R. Ramsey Defendant DATE: July 21, 2011 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-4748 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Keith R. Ramsey PROPERTY: 106 Hampden Avenue, Camp Hill, Pennsylvania 17011 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on September 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in 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 thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. °° J 0 to A w N ?,,, ?roN Z y ?: w o w eDD o ?a S ? C, T?a v s _ . ? o ° ? fD v, _7 . ^? ona m c a ? 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Vl A A K 0 r, r J1VU^1Ai?i 1 !, ^ L CUMBERLAND CONTY PENNSYLVANIA McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Cumberland County Plaintiff Court of Common Pleas V. Keith R. Ramsey Defendant 10-4748 CIVIL Number 10-4748 CIVIL AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS. Edward D. Conway, Esquire, being duly sworn according to law, deposes and says that the following is true and correct to the best of his knowledge and belief: That he is counsel for the above-named Plaintiff, 2. That on October 1, 2010, per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Keith R. Ramsey by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to his/her last-known address of 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. A true and correct copy of the letter and certified receipt, is attached hereto, made a part hereof, and marked as Exhibit "A". That on September 27, 2010, per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Keith R. Ramsey, by posting the same at the mortgaged premises of 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. A true and correct copy of the Sheriff's Returns of Service indicating same is attached hereto, made a part hereof, and marked as Exhibit "B". 4. That on October 8, 2011, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Notice of the filing of the Complaint in Mortgage Foreclosure upon the Defendant, Keith R. Ramsey, through publication in the Cumberland Law Journal. A true and correct copy of the Proof of Publication indicating the same is attached hereto, made a part hereof, and marked Exhibit "C". That on October 19, 2010, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Notice of the filing of the Complaint in Mortgage Foreclosure upon the Defendant, Keith R. Ramsey, through publication in The Sentinel. A true and correct copy of the Proof of Publication indicating the same is attached hereto, made a part hereof, and marked Exhibit "D". SWORN AND SUBSCRIBED BEFORE ME THIS jLhDAY OF , 2011 liM A b.. .. o t f?_ __D ... - - NOTARY PUBLIC CAMMUNWCALTH OF PENNSYLVANIA NOTE%RiAL SEAL Megan C, P,.?a!ueei-Notary Public CIty of Fhiiad?'F.h?a, Philadelphia County MY GTPIAI; c"N ::; ?I?,=S JAN. OFD, 2014 TERRENCE S. MCCABE, ESQUIRE MARC S. WEISBERG, ESQUIRVEj EDWARD D. CONWAY, ESQU MARGARET GAIRO, ESQUI Attorneys for Plaintiff TERRENCE J. McCABE*** MARC S. WEISBERG** EDWARD D.CONWAY- MARGARET GAIRO LISA L. WALLACE+t DEBORAH K. CURRAN+* LAURA H.G. O'SULLIVANt* GAYL C. SPIVAK*= FRANK DUBIN - ANDREW L. MARKOWITZ ., HEIDI R. SPIVAK* SCOTT TAGGART* MARISA COHEN* KATHERINE SANTANGINI- JASON BROOKS f FAITH MIROS ERIN BRADY - KEVIN T MCQUAIL ., RABIHAH SCOTT ALEXANDRA T. GARCIA* CORRIN DEMENT - ABBY K. MOYNIHAN CATHLEEN WELKER Sec --c-law com for licensing key. Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 2080 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 October 1, 2010 Re: Chase Home Finance, LLC v. Keith R. Ramsey Cumberland County; C.C.P.; Number 10-4748 CIVIL Dear Sir or Madam: SUITE 303 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858-7020 SUITE 499 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 FAX (914)-636-8901 Also servicing Connecticut SUITE 100 8101 SANDY SPRING ROAD LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing the District of Columbia SUITE 201 4021 UNIVERSITY DRIVE FAIRFAX, VA 22030 (866) 656-0379 Enclosed please find a true and correct copy of Complaint in Mortgage Foreclosure, along with a copy of the signed Order dated September 14, 2010, the original of which has been filed against you in regard to the above- captioned matter. Very truly yours, TERRENCE J. McCABE TJM/adf Enclosures SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7010 1870 0000 0911 0667 RETURN RECEIPT REQUESTED F N This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. 4`i 7TS 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY 9Sc.j-? Ronny R Anderson Sheriff Jody S SmithA??pzr rJt '4ttuipfrf Chief Deputy `- Richard W Stewart Solicitor •?iF-iGF:IF "HK WtiFF?IFF Chase Home Finance LLC vs. Case Number Keith R. Ramsey 2010-4748 SHERIFF'S RETURN OF SERVICE 09/27/2010 05:27 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 27, 2010 at 1727 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Keith R. Ramsey, pursuant to order of court by posting the premises located at 106 Hampden Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 with a true and correct copy according to law. NOAH CLINE, DEPUTY SHERIFF COST: $47.50 September 28, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and JStateournalaforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law , a legal periodical published in the Borough of Carlisle in the County and State aforesai was established January 2, 1952, and designated by the local courts as the official legal d, 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 8, 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 sub'eci matter of the aforesaid notice or advertisement, and that all allegations in the foregoing J statements as to time, place and character of publication are true. is NOTARIAL SEAL DEBORAH A COLLINS Notery Public [CARLISLE BOROUGH, CUMBERLAND COUNTY My Commisaion Expires Apr 28, 2114 CUMBERLAND LAW JOURNAL NOTICE Cumberland County Court of Common Pleas Number 10-4748 CIVIL Chase Home Finance, LLC Plaintiff V. Keith R, Ramsey Defendant TYPE OF ACTION: CIVIL ACTION/ COMPLAINT IN MORTGAGE FORECLOSURE TO: KEITH R. RAMSEY PREMISES SUBJECT TO FORE- CLOSURE: 106 HAMPDEN AVENUE, CAMP HILL, PENNSYLVANIA 17011 NOTICE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses or objections in writing with the court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE 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 INFORMA- TION 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 RE- DUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 TERRENCE J. McCABE, ESQUIRE ID #: 16496 MARC S. WEISBERG, ESQUIRE ID #: 17616 EDWARD D. CONWAY, ESQUIRE ID #: 34687 MARGARET GAIRO, ESQUIRE ID #: 34419 McCABE, WEISBERG AND CONWAY, P.C. Attorneys for Plaintiff 123 South Broad Street Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Oct. 8 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland James Kleinklaus, Director of Sales and Marketin>r of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): October 14, 2010 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this I 9NM U'A L &'"' Notary Public y commission expires: 9 s?-soe NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My ComrMssion Expires Jan 27, 2014 ?? ?? H5?-Sz any ?. CHASE HOME FINANCE, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEITH R. RAMSEY, ; Defendant NO. 10-4748 CIVIL TERM IN RE: MOTION TO ALLOW SERVICE ON THE DEFENDANT PURSUANT TO PA. RULE OF CIVIL PROCEDURE 430 ORDER OF COURT AND NOW, this 14`h day of September, 2010, upon consideration of the Motion To Allow Service on the Defendant Pursuant to Pa. Rule of Civil Procedure 430, it is ordered and directed that service of the complaint in this case upon Keith R. Ramsey may be made (1) by regular and certified mail at 106 Hampden Avenue, Camp Hill, Pennsylvania 17011, service to be deemed complete upon mailing, (2) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, and (3) by posting of the said property. FOLLOWING SERVICE of original process in the manner prescribed above, service of subsequent papers may be made (1) by regular mail to Defendant's said last known address and (2) by posting of the said property. BY THE COURT, C [ '= F , L b{ S PRAECIPE FOR LISTING CASE FOR TRIAL OT (Must be typewritten and submitted in triplicate)L? Z WYa 10. 10 AM TO THE PROTHONOTARY OF CUMBERLAND COUNTY 'UMBERLAND GO"" PENNSYL'VANlA Please list the following case: ? for JURY trial at the next term of civil court. X? for trial without a jury. --------------------------------------------------------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) X? Civil Action -Law DAWN NELSON ? Appeal from arbitration (other) (Plaintiff) vs. MARK NELSON The trial list will be called on and 11/8/11 Trials commence on 12/5/11 (Defendant) Pretrials will be held on 11/23/11 vs. (Briefs are due S days before pretrials No. 10-4892 Indicate the attorney who will try case for the party who files this praecipe: Stephanie DiVittore, Rhoads & Sinon LLP, P.O. Box 1146, Harrisburg, PA 17108-1146 Indicate trial counsel for other parties if known: Pro Se Term This case is ready for trial. Signed: V' -; 0 Print Name: Stephanie DiVittore Date: August 4, 2011 Defendant Attorney for: 0'yo'%'01 s•0°P4 Q Or* agar gjka (a3oa g 1 Ur MtGt:. A ? !j T 21.,1 OCT 31 rig 1?\;•?? ' l' 1 ER1 AND CCU?J-i / wr McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Cumberland County Court of Common Pleas Plaintiff V. Keith R. Ramsey 10-4748 CIVIL Defendant Number 10-4748 CIVIL AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA Andrew L. Markowitz, Esquire, Esquire, being duly sworn according to law, deposes and says that the following is true and correct to the best of his knowledge and belief: That he is counsel for the above-named Plaintiff, That on August 4, 2011, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant, Keith R. Ramsey, by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to his/her last-known address of 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. A true and correct copy of the letter and certified receipt, is attached hereto, made a part hereof, and marked as Exhibit "A". That on August 10, 2011, in accordance with the attached Court Order, per Plaintiffs conversation with the Sheriffs Office, Plaintiff served a true and correct copy of the Notice of Sheriff s Sale of Real Property upon the Defendant, Keith R. Ramsey, by posting the same at the mortgaged premises of 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. McCabe, WeisberVan¢ Qgnway, P.C. Andrew L. Mark6witz, Esquire Attorney for Plaintiff SWORN AND SUBSCRIBED BEFORE ME THIS 26`h DAY OF OCTOBER, 2011 NOTARY APUBLIC a M M 0 N W EAL H F E'EI ' ''-AL 'NOTARIAL PdO TRIAL iBl?AL Barbara I Moyer- Notay Public City of Philadelphia, Philadelphia County MY COMMISSION EXPIRES JAN. 12, 2014 453-50 C))2-'D Q.. CHASE HOME FINANCE, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEITH R. RAMSEY, Defendant NO. 10-4748 CIVIL TERM IN RE: MOTION TO ALLOW SERVICE ON THE DEFENDANT PURSUANT TO PA. RULE OF CIVIL PROCEDURE 430 ORDER OF COURT AND NOW, this 140' day of September, 2010, upon consideration of the Motion To Allow Service on the Defendant Pursuant to Pa. Rule of Civil Procedure 430, it is ordered and directed that service of the complaint in this case upon Keith R. Ramsey may be made (1) by regular and certified mail at 106 Hampden Avenue, Camp Hill, Pennsylvania 17011, service to be deemed complete upon mailing, (2) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, and (3) by posting of the said property. FOLLOWING SERVICE of original process in the manner prescribed above, service of subsequent papers may be made (1) by regular mail to Defendant's said last known address and (2) by posting of the said property. BY THE COURT, n, EXHIBIT A TERRENCE J. McCABE ^• MARC S. WEISBERG •• EDWARD D. CONWAY MARGARET GAIRO LISA L. WALLACE +t DEBORAH K. CURRAN- LAURA H.G. O'SULLIVAN - GAYL C. SPIVAK=• ANDREW L. MARKOWITZ HEIDI R. SPIVAK SCOTT T.TAGGART• MARISA J. COHEN JASON BROOKS* ERIN M. BRADY •• KEVIN T. McQUAIL• ALEXANDRA T. GARCIA • CORRIN DEMENT- ABBY K. MOYNIHAN CATHERINE WELKER `•' ANTOINETTE N. MOORE -- CHRISTINE GRAHAM • MELISSA A. SPOSATO ^ HEATHER WEJNERT DEBRA A. STUMP >_ RICHARD J. SUZOR, JR. See www.mwc-law.wm for licensing kev Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 2080 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 August 4, 2011 Re: Chase Home Finance, LLC VS. Keith R. Ramsey Cumberland County; No. 10-4748 CIVIL Premises: 106 Hampden Avenue, Camp Hill, Pennsylvania 17011 Dear Keith R. Ramsey: Enclosed is a Notice of Sheriffs Sale relative to the above-captioned matter. Very truly yours, Allyson Marcinkiewicz, Legal Assistant McCabe, Weisberg and Conway, P.C. TJM/amz Enclosure SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7010 3090 0000 8825 6788 RETURN RECEIPT REQUESTED SUITE 303 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858-7020 SUITE 499 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 GENERAL FAX (914) 636-8901 MEDIATION ONLY FAX (914) 819-5505 Also servicing Connecticut SUITE 100 8101 SANDY SPRING ROAD LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing the District of Columbia SUITE 201 4021 UNIVERSITY DRIVE FAIRFAX, VA 22030 (866) 656-0379 This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used,for that purpose. zv OFFICI I, U S E O C 11 t rT1 i?g ? 1 J tsa two et- br r. npt ?.A AWL uxn J :,v ?- or pip 8qz No. `"' twist Lin ? U f X ^g a F. U ?_ ? r ?4 ! Cd p? rt u Z ? 7y m W ? q ,? ? ? N C1. N L1+ H 0 a 0 0 0 A4 *- U GLr 00 U u r y' y 33 rr O Q C? ^ ? e '- Q .? ? ? ^? 4 VJ N ` 5c a y lMl 'O •. F L+ U L1r rTr U . ?' C> n. =? . ' . Z ,i , yi Y?AMt ? H C-JA Q ?' tn et u 1 «3 d a a O e F" W SS v Q M O 4L SHERIFF'S OFFICE OF CUMBERLAND COUNTY r i ,? r F Ronny R Anderson Sheriff Jody S Smith P } 3 Chief Deputy Richard W Stewart ?Cr+LU-,vid s 4INS`t LV N i Solicitor ?=-" t Chase Home Finance LLC Case Number vs. 2010-4748 Keith R. Ramsey SHERIFF'S RETURN OF SERVICE 06123/2011 02:38 PM - Deputy Ronald Hoover, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 106 Hampden Avenue, Camp Hill, PA 17011, Cumberland County. 07/01/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Keith R. Ramsey, but was unable to locate the Defendant it his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 106 Hampden Avenue, Camp Hill, PA 17011, property is vacant, mail is still delivered there. 08/10/2011 01:05 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Keith R. Ramsey, pursuant to Order of Court by "Posting" the premises located at 106 Hampden Avenue, Hampden Township, Camp Hill, PA 17011, Cumberland County with a true and correct copy according to law. 08/13/2011 As directed by Margaret Gairo, Attorney for the Plaintiff, Sheriffs Sale Continued to 11 /2/2011 11/02/2011 Ronny R Anderson, Sheriff, being duly sworn according to iaw, 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on November 02, 2011 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Margaret Gairo, on behalf of the Bank of Federal National Mortgage Association, 1900 Market Street, # 800, Philadelphia, PA 19103, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $896.11 SO ANSWERS, 0?0222. 'K zw? December 29, 2011 RON W R ANDERSON, SHERIFF ?o y LL 5U 31 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 1649E MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34681 MARGARET CAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance, LLC Plaintiff v. Keith R. Ramsey Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-4748 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 106 Hampden Avenue, Camp Hill, Pennsylvania 17011, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Keith Ramsey 106 Hampden Ave Camp Hill, Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Cumberland County Adult Probation Address i C'ourthonce Square Carlisle, Pennsylvania 17013 William H. Paul, DDS c/o M.L. Van Eck, Esq. P.O. Box 6662 Harrisburg, Pennsylvania 17112 4. Name and address of the last recorded holder of every mortgage of record: Name Address ERA Mortgage 3000 Leadenhalt Road Mount Laurel, New Jersey 08504 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 which may be affected by the sale: Name Address None 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 Tenants/Occupants Address 106 Hampden Avenue Camp Hill, Pennsylvania 17011 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8"' Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales United States of America Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States 8. Name and address of Attorney of record: Name None Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 31 1 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address 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. Section 4904 relating to unsworn falsification to authorities. March 8, 2011 DATE TERREN E J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW Chase Home Finance, LLC I COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Keith R. Ramsey Number 10-4748 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Keith R. Ramsey 106 Hampden Avenue Camp Hill, Pennsylvania 17011 Your house (real estate) at 106 Hampden Avenue, Camp Hill, Pennsylvania 17011 is scheduled to be sold at Sheriffs Sale on September 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $136,277.52 obtained by Chase Home Finance, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to Chase Home Finance, LLC the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 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. 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 the following notice on how to obtain an attorney.) 1 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 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 a 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at the Southwest: corner of Hampden Avenue and Courtland Street on the hereinafter mentioned plan of lots; thence South 87 degrees 21 minutes West along the southern side of Courtland Street 80 feet to a point at the division lines of lots numbered 159 and 160; thence South l degree 52 minutes East along said division line 86.51 feet to a point at the division line of Lots numbered 158 and 159; thence South 79 degrees 38 minutes East along said division line a distance of 83.3 I feet to a point on the division line a distance of 83.31 feet to a point on the western side of Hampden Avenue; thence North 2 degrees 39 minutes West along said Hampden Avenue, 105.26 feet to a point the place of beginning. HAVING thereon erected a sinnle one story brick ranch dwelling, said premises being known and numbered as 106 Hampden Avenue, Camp Hill, Pennsylvania. BEING Lot #159 on the general plan of Section 2 and 3 of Clearview Farms recorded in and for County of Cumberland in Plan Book 9 page 6. Parcel No.: 10-21-0279-142 106 Hampden Avenue, Camp Hill, Pennsylvania 17011. BEING the same premises which KEITH R. RAMSEY, SINGLE MAN by deed dated April 2, 2004 and recorded April 8, 2004 in the office of the Recorder in and for Cumberland County in Deed Book 262, Page 2101, granted and conveyed to Keith R. Ramsey, single man in fee. 'TAX MAP PARCEL NUMBER: 10-21-0279-142 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-4748 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE, LLC Plaintiff (s) From KEITH R. RAMSEY (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (?) 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 $136,277.52 L.L.$.50 Interest from 3/09/11 - - 54,099.20 at $22.40 Attv's Comm °ro Due Prothy $2.00 Atty Paid 5:258.50 Other Costs Plaintiff Paid Date: 31151:11 Davi , otary BuelPrthon (Seal) By: Deputy REQUESTING PARTY: Name: MARGARET GAIRO, ESQUIRE Address: MCCABE WEISBERG AND CONWAY 12.3 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 34419 TRUE COPY FROM RECORD In Testimony w.,erenf, ! nee unto set my hand and the seal of said Court at CarGslz, Pa. This day of 20 __LJ__ Prothonotary t_)ri i/Iav J. i . () ? # HIC °?IICIA I! I.eVled upon the delendant`s interest in ttic real property situated its Hampden ownship. (Alin.bertand County, PA. Known and numbered as. 106 Hampden Avenue, Camp Hill, more Cully described on Exhibit -A" tiled with this writ and by this reference incorporated herein. Date: /lay .t t teal Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-4748 Civil Chase Home Finance LLC vs. Keith R. Ramsey Atty.: Margaret Gairo ALL THAT CERTAIN piece or parcel of land, situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at the Southwest corner of Hampden Avenue and Courtland Street on the hereinafter mentioned plan of lots; thence South 87 degrees 21 minutes West along the southern side of Courtland Street 80 feet to a point at the division lines of lots numbered 159 and 160; thence South 1 degree 52 minutes East along said division line 86.51 feet to a point at the division line of Lots numbered 158 and 159; thence South 79 degrees 38 minutes East along said division line a distance of 83.31 feet to a point on the divi- sion line a distance of 83.31 feet to a point on the western side of Hampden Avenue; thence North 2 degrees 39 minutes West along said Hampden Avenue, 105.26 feet to a point the place of beginning. HAVING thereon erected a single one story brick ranch dwelling, said premises being known and numbered as 106 Hampden Avenue, Camp Hill, Pennsylvania. BEING Lot #159 on the general plan of Section 2 and 3 of Clearview Farms recorded in and for County of Cumberland in Plan Book 9 page 6. Parcel No.: 10-21-0279-142. BEING the same premises which KEITH R. RAMSEY, SINGLE MAN by deed dated April 2, 2004 and re- corded April 8, 2004 in the office of the Recorder in and for Cumberland County in Deed Book 262, Page 2101, granted and conveyed to Keith R. Ramsey, single man in fee. TAX MAP PARCEL NUMBER: 10 21 0279 142. 54 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: July 15, July 22 and July 29, 2011 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. JLisa Marie Cope, Editor SWORN TO AND SUBSCRIBED before me this X29 day of July, 2011 // //Notary '%01ARIAL SEAL DEBORAH GoINS Notary b G LISLE BOROUGH. CU CB ARLr 23D? O } ITl' MY commissio_. x..,....-p.. "'.'"a 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 Z4fPatriot 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 Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book °M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 07115111 07122111 07129111 JJ ! Sworn to and suby(cribed beforeA4 thil 18,day of August, 2011 A.D. ij XA, Notary Public CQMMONW_EAl.trr ()F PENNSYLVANIA Notarial Sea! Sherrie L. Ki9ier. Notary pYjt)Nc ewer Paxton Twrj.,. Dauphin County My Commission Expires Nov. 26, 201.! ?errsh! nm. ar - „- '?iirrn ^f Ne tarie- 201"748 CWN TWm Chop ftme Ftnancf' U.C VS Keith R. Ramsey Atty. Marlwat Qalro ALL THAT CERTAIN piece or parcel of land, situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at the Southwestcomer of Hampden Avenue and Courtland Street on the hereinafter mentioned plan of lots; thence South 87 degrees 21 minutes West along the southern side of Courtland Street 80 feet to a point at the division lines of lots numbered 159 and 1%, thence South l degree 52 minutes East along said division line 86.51 feet to a point at the division line of Lots numbered 158 and 159; thence South 79 degrees 38 minutes East Wong said division line a distance of 83.31 feet to a point on the division line a distance of 83.31 feet to a point on the western side of Hampden Avenue; thence North 2 degrees 39 minutes West along said Hampden Avenue, 105.26 feet to a point the place of beginning. HAVING thereon erected a single one story brick ranch dwelling, said premises being known and nunftred as 106 Hampden Avenue; Camp Hill, Pennsylvania. BEING LOt #159 on the general plan of Section 2 and 3 of Clearview Farms recorded in and for County of Cumberland in Plan Book 9 page 6. Parcel No.: 10-21-0279-142 BEING the same premises which KEITH R. RAMSEY, SINGLE MAN by deed dated April 2, 2004 and recorded April 8, 2004 in the office of the Recorder in and for Cumberland County in Deed Book 262, Page 2101, granted and conveyed to Keith R. Ramsey, sittgle man in fee. TAX MAP ?ARM NUMBER: 1021 0279142 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: 1. Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Federal National Mortgage Association is the grantee the same having been sold to said grantee on the 2 day of November A.D., 2011, under and by virtue of a writ Execution issued on the 15 day of March, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 4748, at the suit of Chase Home Finance LLC against Keith R. Ramsey is duly recorded as Instrument Number 2.01136331. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of My f WIloWWO NL2014