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Home My WebLink About12-0706F=ILED-OFFICE C THE PROTHONOTAR' 2012 FEB - 6 AM 9: 17 CUMBERLAND COUNTY PENNSYLVANIA PHELAN HALLINAN & SCHMIEG, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY 839 NORTH WEST STREET CARLISLE, PA 17013-1435 Defendant 287693 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM /? NO. ;w I d --?w Cavil CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 287693 0 %a97.3 424A d -7e to Qlo NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 287693 Plaintiff is WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY 839 NORTH WEST STREET CARLISLE, PA 17013-1435 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 04/15/2008 TRACY RAMSEY and LEON G. RAMSEY, JR made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS A NOMINEE FOR LEND AMERICA, A NEW YORK CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200824514. By Assignment of Mortgage recorded 12/04/2009 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 200940444. Said Mortgage was modified as set forth in the modification agreement recorded September 10, 2010, in Instrument No. 201025272. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File #: 287693 . 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2011 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage as of 12/28/2011: Principal Balance $138,597.14 Interest $3,570.05 through 12/28/2011 Late Charges $162.16 Property Inspections $100.00 Escrow Deficit $1,433.91 TOTAL $143,863.26 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon. File #. 287693 9. LEON G. RAMSEY, JR was a co-record owner of the mortgaged premises as a tenant by the entirety. By virtue of LEON G. RAMSEY, JR's death on or about 06/11/2011, his ownership interest was automatically vested in the surviving tenant by the entirety. 10. Plaintiff hereby releases LEON G. RAMSEY, JR, from liability for the debt secured by the mortgage. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $143,863.26, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHEL INAN & SCHMIEG, LLP By: T?i Rob sick, Esquire Attorney for Plaintiff File #: 287693 LEGAL DESCRIPTION ALL THAT CERTAIN LOT OR GROUND SITUATE IN THE BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE WEST BY NORTH WEST STREET; ON THE NORTH BY LOT NO. 1, BLOCK 21 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; ON THE EAST BY A 16 FOOT WIDE ALLEY; AND ON THE SOUTH BY PROPERTY NOR OR FORMERLY OF MRS. SUSAN MORRISON; CONTAINING 25 FEET IN FRONT ON SAID WEST NORTH STREET AND EXTENDING IN DEPTH AN EVEN WIDTH 190 FEET TO THE AFORESAID ALLEY, AND BEING LOT NO. 2, BLOCK 21, IN A PLAN OF LOTS LAID OUT BY THE CARLISLE LAND AND IMPROVEMENT COMPANY, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN MISC. BOOK 11, PAGE 572. SAID LOT OF GROUND HAS THEREON ERECTED A TWO AND ONEHALF STORY FRAME DWELLING HOUSE AND NECESSARY OUTBUILDINGS KNOWN AS 839 NORTH WEST STREET. PROPERTY ADDRESS: 839 NORTH WEST STREET, CARLISLE, PA 17013-1435 PARCEL # 06-19-1643-243. File #: 287693 VERIFICATION Ismael Hernandez, hereby states that(gshe is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter, thateshe is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best o is her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Ismael Hernandez DATE: ?.? Title: Vice President Loan Documentation File #287693 Name: RAMSEY AND BOONE 032-PA-V3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r i _Cilai Sheriff ?tiitr a( ?ninG?r/ .t ii,.. i? nay {. Jody S Smith Chief Deputy 2012 MAR 16 AM $: 4 Richard W Stewart Solicitor CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, NA vs. Case Number . Tracy Ramsey 2012-706 SHERIFF'S RETURN OF SERVICE 03/12/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on March 12, 2012 at 1130 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Tracy Ramsey. After several attempts the Complaint in Mortgage Foreclosure has expired. SHERIFF COST: $58.00 March 12, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF 'Cl gountySuite Shenft. Te,ec oft. Inc. Air, "? OF Phelan Hallinan & Schmieg, LLPa' i` 1617 JFK Boulevard, Suite 140A/1 JUL One Penn Center Plaza ?h 9:40 Philadelphia, PA 19103 215-563-7000 ?$ytVA AA « WELLS FARGO BANK, N.A. Plaintiff vs. TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY Defendant CUMBERLAND County No. 2012-706-CIVIL MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan & Schmieg, L.L.P., moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant, TRACY RAMSEY, by first class mail to TRACY RAMSEY at the mortgaged premises, 839 NORTH WEST STREET, CARLISLE, PA 17013; posting of the mortgaged premises, 839 NORTH WEST STREET, CARLISLE, PA 17013; and publication pursuant to Pa. R.C.P. 430, and in support thereof avers the following: 1. Attempts to serve Defendant, TRACY RAMSEY, personally with the Complaint have been unsuccessful. The Sheriff of CUMBERLAND County attempted to serve the Defendant at the mortgaged premises, 839 NORTH WEST STREET, CARLISLE, PA 17013. As indicated by the Return of Service, no service was made as there was no response to the attempts made by the Sheriff's Deputy. A true and correct copy of the Return of Service is attached hereto, made part hereof, and marked as Exhibit "A". Attorney for Plaintiff Court of Common Pleas Civil Division 287693 2. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendant. A true and correct copy of an affidavit of due diligence setting forth the specific inquiries as to the Defendant's whereabouts and the results thereof is attached hereto, made part hereof, and marked as Exhibit "B". 3. Plaintiff contacted the Prothontary's Office and as of June 26, 2012, no Judge has previously entered a ruling in this case. 4. In accordance with CUMBERLAND County Local Rule 208.2(d), Plaintiff sent a copy of its Proposed Motion for Special Service and Order to the Defendant on May 22, 2012 and requested Defendant's concurrence. Plaintiff did not receive any written response from the Defendant. A true and correct copy of Plaintiffs May 29, 2012 letter and postmarked certificate of mailing pursuant to Local Rule 208.2(d) attached hereto, made part hereof, and marked Exhibit "C". 5. Plaintiff has reviewed its internal records and has not been contacted by the Defendant as of June 29, 2012 to bring loan current. 6. Plaintiff submits that it has made a good faith effort to locate the Defendant but has been unable to do so. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail; posting; and by publication. Respectfully submitted, PHELAN 4A4LINAN & SCHMIEG, LLP Date: By: a ew G rushwood, Esq., Id. No.310592 Atto or Plaintiff 287693 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff vs. TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY Defendant Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 2012-706-CIVIL MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT 1. FACTUAL BACKGROUND Attempts to serve Defendant, TRACY RAMSEY, with the Complaint have been unsuccessful. The Sheriff of CUMBERLAND County attempted to serve the Defendant at the mortgaged premises, 839 NORTH WEST STREET, CARLISLE, PA 17013. As indicated by the Return of Service, no service was made. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to discover the whereabouts of the Defendant as evidenced by the affidavit of due diligence setting forth the specific inquiries as to the Defendant's whereabouts and the results thereof. Further, Plaintiff's counsel has reviewed its internal records and has not been contacted by the Defendant as of June 29, 2012 to bring loan current. Consequently, Plaintiff submits that it has made a good faith effort to locate the Defendant but has been unable to do so. 287693 II. LEGAL AUTHORITY Pennsylvania Rule of Civil Procedure 430(a) specifically states: If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Pa.R.C.P. 430(a) (2009). In particular: An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends, and employers of the defendant, and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. Id. at 430(a) n. Similarly, the Pennsylvania Superior Court has gone on to explain that, "While by no means exhaustive, this Note is at least indicative of the types of procedures contemplated by the legislature when enacting Rule 430." Deer Park Lumber, Inc. v. Major, 384 Pa. Super. 625, 633, 559 A.2d 941, 946 (1989), appeal denied, 525 Pa. 582, 575 A.2d 113 (1990). Only after such proof has been offered is the Court authorized to direct another method of substitute service. See id. In the instant case, as indicated by the Return of Service, the Sheriff has been unable to serve the Complaint. Plaintiff has made a good faith effort to discover the whereabouts of the Defendant as evidenced by the affidavit of due diligence. Therefore, Plaintiff respectfully requests an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail, posting, and publication. 287693 III. CONCLUSION As indicated by the Return of Service, the Sheriff has been unable to serve the Complaint upon the Defendant. Plaintiff has made a good faith effort to discover the whereabouts of the Defendant as evidenced by its affidavit of due diligence. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail, posting, and publication. Respectfully submitted, PHEL INAN & SCHMIEG, LLP Date: By: atth w G. B shwood, Esq., Id. No.310592 Attome laintiff 287693 Exhibit "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF CE OF THE 5"66 F F!LED-OFF ICE '1` THE PROTHON01' '2012 MAR 16 AM 8: 45 CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, NA vs. Case Number Tracy Ramsey 2012-708 SHERIFF'S RETURN OF SERVICE 03/12/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on March 12, 2012 at 1130 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Tracy Ramsey. After several attempts the Complaint in Mortgage Foreclosure has expired. SHERIFF COST: $58.00 SO ANSWERS, 6z - --- March 12, 2012 RON R ANDERSON, SHERIFF ;c; GPUMySuile Smartt 3 ale,.^,50.1 ue: Exhibit "B" AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 287693 Attorney Firm: Phelan, Hallinan & Schmieg, LLP Subject: Leon G. Ramsey Jr. (Deceased) & Tracy Ramsey Property Address: 839 North West Street, Carlisle, PA '17013 1. CREDI'T' INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Leon G. Ramsey Jr. - xxx-xx-0513 Tracy Ramsey - xxx-xx-2327 8. EMPLOYMENT SEARCH Leon G. Ramsey Jr. & Tracy Ramsey - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Leon G. Ramsey Jr. & Tracy Ramsey reside(s) at: 839 North West Street, Carlisle, PA 17013. IT, INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases, which indicated that Leon. G. Ramsey Jr. & Tracy Ramsey reside(s) at: 839 North West Street, Carlisle, PA 17013 and Tracy Ramsey reside(s) at: 116 Elm Street, Carlisle, PA 17013. On 01-09-] 2 our office made several telephone calls to the subjects' phone number (717) 258-5385 and received the following information: tic) answer. On 01-09-12 our office made several telephone calls to the subject's phone number (717) 249-0592 and received the following information: no answer. 111. INQUIRY OF NEIGHBORS On 01-09-12 our office made several phone calls in an attempt to contact Joanne Kell (717) 258-1868,838 North West Street, Carlisle, PA 17013: no answer. On 01-09-12 our office made a phone call in an attempt to contact Jack A. Myers (717) 245-8533, 837 North West Street, Carlisle, PA 17013: spoke with an unidentified female who could not confirm that the subjects reside(s) at 839 North West Street, Carlisle, PA 17013. On 01-09-12 our office made a phone call in an attempt to contact Nancy 1. Hershey (717) 243-0224,835 North West Street, Carlisle, PA 17013: spoke with an unidentified female who could not confirm that the subjects reside(s) at 839 North West Street, Carlisle, PA 17013. IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 01-09-12 we reviewed the National Address database and found the following information: Leon G. Ramsey Jr. & Tracy Ramsey - 839 North West Street, Carlisle, PA 17013. B. ADDITIONAL. ACTIVE MAILING ADDRFISSF..S Per our inquiry of creditors, the following is a possible mailing address: no addresses on file. V. OTHER INQUIRIES A. DEATH RECORDS .As of 01-09-12 Vital Records and all public databases have a death record on file for Leon G. Ramsey Jr. & have no death record on file for Tracy Ramsey. VI. ADDITIONAL INFORMATION OF SUBJECT A. YEAR OF BIRTH Leon G. Ramsey Jr. - 1966 Tracy Ramsey -1970 B. DATE OF DEATH Leon G. Ramsey Jr. - 06-11-2011 C. A.K.A. Tracy Lynne Ramsey; Tracey L. Boone * Our accessible databases have been checked and cross-referenced for the above named individual(s). * Please be advised our database information indicates the subject resides at the current address. I hereby verify that the statements made herein are true and correct to the best of any knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S. Sec. 4904 relating to unsworn falsification to authorities. 'l ho above wfonnation is obtatned from available public wCords and we aces truly liable for the cost of the affidavit, Exhibit "C" tYy?,y S ? N ? F r e p a° y A 0. h+ O ? p a 0 4) a ? a O a „z 00 N d cn x a b ? b d! S zQ C N Im I-t ILn Po In I- py? ? ?3 Q 0 ? 9? p e7 H 0p 9 O ? b 0 O X •p C 0 LS n 0 Ys?u ? haw aw i8 ao P. z> F I 4 N N O? N Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 Kathleen Lake, Ext 1316 Representing Lenders in Service Department Pennsylvania and New Jersey May 29, 2012 TRACY RAMSEY 839 NORTH WEST STREET CARLISLE, PA 17013 RE: WELLS FARGO BANK, N.A. v. TRACY RAMSEY Premises Address: 839 NORTH WEST STREET, CARLISLE, PA 17013-1435 CUMBERLAND County, No. 2012-706-CIVIL Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, service of the complaint by first class mail and posting of the mortgaged premises. Please respond to me within one week, by Jund4, 2012. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly, Very truly yours, Aljis0n I-". ylls, Esq., Id. No.309519 Attorney t' P if[if 287693 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff WELLS FARGO BANK, N.A. Court of Common Pleas Plaintiff Civil Division VS. : CUMBERLAND County TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. No. 2012-706-CIVIL RAMSEY : Defendant CERTIFICATION OF SERVICE The undersigned hereby certifies that a copy of the Motion for Service Pursuant to Special Order of Court, Memorandum of Law, Proposed Order and attached exhibits have been sent to the individual as indicated below by first class mail, postage prepaid, on the date listed below. TRACY RAMSEY at: 839 NORTH WEST STREET CARLISLE, PA 17013 The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Respectfully submitted, PHELANJJAI? 1NAN & SCHMIEG, LLP Date: By V.. Brushwood, Esq., Id. No.310592 for Plaintiff 287693 WELLS FARGO BANK, N.A., Plaintiff V. TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY, Defendant NO. 2012-706 CIVIL TERM IN RE: MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT ORDER OF COURT AND NOW, this ?'Vday of July, 2012, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, it is ordered that service of the Complaint in this case upon the Defendant, Tracy Ramsey may be made (1) by first- class and certified mail at the last known address, 839 North West Street, Carlisle, Pennsylvania 17013, service to be deemed complete upon mailing; (2) by posting the Complaint on the most public portion of the property located at 839 North West Street, Carlisle, Pennsylvania 17013; and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. SUBSEQUENT papers may be served by first-class mail to Defendant at the aforesaid North West Street address with service to be deemed complete upon mailing. COUNSEL FOR PLAINTIFF is hereby DIRECTED to file a certificate of service with the Prothonotary's office to ensure compliance with this Court Order. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT BY THE COURT, Distribution: Thomas cey, C.P.J. ? Matthew G. Brushwood, Esq. Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia PA 19103 c - N ---? , te- ro ? Tracy Ramsey r o 839 North West Street Carlisle, PA 17013 <? -+o o Tracy Ramsey ZQ 3 116 Elm Street Carlisle, PA 17013 evp ? es gta` /,w -71A/ A PHELAN I-IALLINAN & SCHMIEG, LLP John M. Kollesnik, Esq., Id. No. 308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS VARGO BANK, N.A. Plaintiff F FLED-0E= E}i;.E THE PROTNONOTAR)' 2112 AUG 22 AEI 10: 59 CUMBERLAND COUNTY PENNSYLVANIA : COURT OF COMMON PLEAS CIVIL DIVISION VS. ,TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY Defendant CUMBERLAND COUNTY No. 2012-706-CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE 'TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captionedl, matter. Date: August 20, 2012 jhk/kpl, Svc Dept. File# 287693 PHELAN HAJAANAN & SCHMIEG, LLP Johne6ik!1ffsq., Id. No. 308877 AttorFA for Plaintiff By: (P j a PHELAN HALLINAN & SCHMIEG, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. vs. TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS ~ ° -Q 3 CIVIL DIVISION cap cn .... No. 2012-706-CIVIL rte- ~ ~"`~ PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ~ ~ ~ ANSWER AND ASSESSMENT OF DAMAGES ~' TO THE PROTHONOTARY: --~ ~ -,- ~ Kindly enter judgment in favor of the Plaintiff and against TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY, Defendant for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint TOTAL $143,863.26 $143,863.26 I hereby certify that (1) the Defendant's last known address is 839 NORTH WEST STREET, CARLISLE, PA 17013-1435, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date / --, an Lobb, Esq., Id. No.312174 ttorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~ • ~~ ~~~ C~ PROTHONOTARY e I~h 287693 ~~ -D r-- ~~ o° _ -`~'~, a -,~ ~~ °rn .:~ ,--, -~: 10.50 P~ p17~ Iac~s3y~ ~ a8a9~~ ~ ~l~~I~ PHELAN HALLINAN & SCHMIEG, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. vs. TRACY RAMSEY A!K/A TRACY BOONS A/K/A TRACY L. RAMSEY Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.2012-706-CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant TRACY RAMSEY A/K/A TRACY BOONS A/K/A TRACY L. RAMSEY is over 18 years of age and resides at 839 NORTH WEST STREET, CARLISLE, PA 17013-1435. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date _~, than Lobb, Esq., Id. No.312174 Attorney for Plaintiff 287693 WELLS FARGO BANK, N.A: COURT OF COMMON PLEAS Plaintiff CIVIL DNISION v, TRACY RAMSEY, A/K/A TRACY BOONE, NO. 2012-706-CIVIL AIKIA TRACY L. RAMSEY Defendant{s) CUMBERLAND COUNTY TO; TRACY RAMSEY, A/KIA TRACY BOONE, A/K/A TRACY L. RAMSEY 839 NORTH WEST STREET CARLISLE, PA 17013-1435 DATE OF NOTICE:~ ~j~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERREU TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AiV ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT' MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH 1NFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO H1RE 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17033 {717}240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAIv~ COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717} 2`4, 9-3166 By: .1 tt~at~, Lobb, Esq., Id. No.312174 tY~n~~ir for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 287b93 (Rule of Civil Procedure No. 236) -Revised WELLS FARGO BANK, N.A. CUMBERLAND COUNTY vs. COURT OF COMMON PLEAS TRACY RAMSEY CIVIL DIVISION AiKJA TRACY BOONE A/KiA TRACY L. RAMSEY No. 2012-706-CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on B w If you have any questions concerning this matter please contact: Phelan Hallinan & Schmieg, LLP Jonathan Lobb, Esquire Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 287693 FILED-OPF iCE OF THE PROTHONOTARY Phelan Hallinan, LLP i ��' _2 �� ; Allison F. Zuckerman, Esq:, Id. No.309 1 A ORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 CUMBERLAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 allison.zuckerman@phelanhallinan.com 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. No.: 2012-706-CIVIL RAMSEY Defendant PLAINTIFF'S MOTION TO REASSESS DAMAGES Plaintiff,by its Attorneys, Phelan Hallinan, LLP,moves the Court to direct the Prothonotary to amend the judgment in this matter, and in support thereof avers the following: 1. Plaintiff commenced this foreclosure action by filing a Complaint on February 6, 2012. 2. Judgment was entered on November 13, 2012 in the amount of$143,863.26. A true and correct copy of the praecipe for judgment is attached hereto, made part hereof, and marked as Exhibit"A". 3. Pursuant to Pennsylvania Rule of Civil Procedure 1037(b)(1),a default judgment containing a dollar amount must be entered for the amount claimed in the complaint and any item which can be calculated from the complaint, i.e. bringing the interest current. However,new items cannot be added at the time of entry of the judgment. 4. The Property is listed for Sheriffs Sale on June 5, 2013. 287693 5. Additional sums have been incurred or expended on Defendant's behalf since the Complaint was filed and Defendant has been given credit for any payments that have been made since the judgment. The amount of damages should now read as follows: Principal Balance $138,597.14 Interest Through May 1, 2013 $13,339.92 Late Charges $162.16 Legal fees $1,800.00 Cost of Suit and Title $2,227.12 Property Inspections $295.00 Mortgage Insurance Premium/Private Mortgage Insurance $931.51 Mortgage Insurance Premium to be paid $97.40 Escrow to be paid $1,346.14 Escrow Deficit $4,253.07 TOTAL $163,049.46 6. The judgment formerly entered is insufficient to satisfy the amounts due on the Mortgage. 7. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to inclusion of the figures set forth above in the amount of judgment against the Defendant. 8. Plaintiff's foreclosure judgment is in rem only and does not include personal liability, as addressed in Plaintiff's attached brief. 9. In accordance with Cumberland County Local Rule 208.3(9),Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on April 24, 2013and requested the Defendant's Concurrence. Plaintiff did not receive any response from the Defendant. A true and correct copy of Plaintiff's letter pursuant to Local Rule 208.3(9) and certification of mailing are attached hereto, made part hereof, and marked as Exhibit`B". 110. In compliance with Cumberland County Local Rule 209.3(a)(2), Plaintiff avers that Judge Thomas A. Placey entered an order for Service Pursuant to Special order of Court dated July 6, 2012 . 287693 WHEREFORE,Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. Phelan Hallinan, LLP DATE: 1 By: llisauc , Esquire ATTO E FOR PLAINTIFF 287693 Phelan Hallinan, LLP , Allison F. Zuckerman, Esq., Id.No.309519 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 al li son.zuckerman@phelanhallinan.com 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. No.: 2012-706-CIVIL RAMSEY Defendant MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION TO REASSESS DAMAGES I. ' BACKGROUND OF CASE TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY executed a Promissory Note agreeing to pay principal, interest, late charges, real estate taxes, hazard insurance premiums, and mortgage insurance premiums as these sums became due. Plaintiffs Note was secured by a Mortgage on the Property located at 839 NORTH WEST STREET, CARLISLE, PA 17013-1435. The Mortgage indicates that in the event of a default in the mortgage, Plaintiff may advance any necessary sums, including taxes, insurance, and other items, in order to protect the security of the Mortgage. In the instant case, Defendant defaulted under the Mortgage by failing to tender numerous, promised monthly mortgage payments. Accordingly, after it was clear that the default would not be cured, Plaintiff commenced the instant mortgage foreclosure action. Judgment was subsequently entered by the Court, and the Property is currently scheduled for Sheriffs Sale. • 287693 Because of the excessive period of time between the initiation of the mortgage foreclosure action, the entry of judgment and the Sheriffs Sale date, damages as previously assessed are outdated and need to be adjusted to include current interest, real estate taxes, insurance premiums, costs of collection, and other expenses which Plaintiff has been obligated to pay under the Mortgage in order to protect its interests. It is also appropriate to give Defendant credit for monthly payments tendered through bankruptcy, if any. II. LEGAL ARGUMENT TO AMEND PLAINTIFF'S IN REM JUDGMENT It is settled law in Pennsylvania that the Court may exercise its equitable powers to control the enforcement of a judgment and to grant any relief until that judgment is satisfied. 20 P.L.E., Judgments § 191. Stephenson v. Butts, 187 Pa.Super. 55, 59, 142 A.2d 319, 321 (1958). Chase Home Mortgage Corporation of the Southwest v. Good, 537 A.2d 22, 24 (Pa.Super. 1988). The Pennsylvania Superior Court has repeatedly cited the right of a foreclosing creditor to amend its judgment prior to the Sheriff s sale. Nationsbanc Mortgage Corp. v. Grillo, 827 A.2d 489 (Pa.Super. 2003). Morgan Guaranty Trust Co. of N.Y. v. Mowl, 705 A.2d 923 (Pa. Super. 1998). Union National Bank of Pittsburgh v. Cion oli, 407 Pa.Super. 171, 595 A.2d 179 (1991). The Supreme Court of Pennsylvania recognized in Landau v. Western Pa.Nat. Bank,445 Pa. 117, 282 A.2d 335 (1971),that the debt owed on a Mortgage is subject to change and, in fact, can be expected to change from day to day because the bank must advance sums in order to protect its collateral. Because a Mortgage lien is not extinguished until the debt is paid, Plaintiff must protect its collateral up until the date of sale. Beckman v. Altoona Trust Co., 332 Pa. 545, 2 A.2d 826 (1939). Because a judgment in mortgage foreclosure is strictly in rem, it is critical that the judgment reflect those amounts expended by the Plaintiff in protecting the property. Meco Reality 287693 Company v. Burns, 414 Pa. 495,200 A.2d 335 (1971). Plaintiff submits that if it goes to sale without the requested amended judgment, and if there is competitive bidding for the Property, Plaintiff will suffer a significant loss in that it would not be able to recoup monies it advanced to protect its interests. Conversely, amending the in rem judgment will not be detrimental to Defendant as it imputes no personal liability. In B.C.Y. v. Bukovich,the Pennsylvania Superior Court reiterated its long standing rule that a Court has the inherent power to correct a judgment to conform to the facts of a case. 257 Pa. Super. 157, 390 A.2d 276 (1978). In the within case,the amount of the original judgment does not adequately reflect the additional sums due on the Mortgage due to Defendant's failure to tender payments during the foreclosure proceeding and the advances made by the mortgage company. The Mortgage plainly requires the mortgagor to tender to the mortgagee monthly payments of principal and interest until the Promissory Note accompanying the Mortgage is paid in full. The mortgagor is also required to remit to the mortgagee sufficient sums to pay monthly mortgage insurance premiums, fire insurance premiums,taxes and other assessments relating to the Property. The mortgagor has breached the terms of the Mortgage, and Plaintiff has been forced to incur significant unjust financial losses on this loan. III. THE FORECLOSURE JUDGMENT IS IN REM ONLY The within case is a mortgage foreclosure action,the sole purpose of which is to take the mortgaged property to Sheriffs Sale. Pennsylvania law makes clear that an action in mortgage foreclosure is strictly in rem and does not include any personal liability. Newtown Village Partnership v. Kimmel,424 Pa. Super 53, 55, 621 A.2d 1036, 1037 (1993). Signal Consumer 287693 Discount Company v. Babuscio, 257 Pa. Super 101, 109, 390 A.2d 266, 270 (1978). Pennsylvania Rule of Civil Procedure 1141(a). However, Pennsylvania law requires that the foreclosure action demand judgment for the amount due. Pa.R.C.P. 1147(6). The purpose of the dollar amount in the in rem judgment is for bidding at the Sheriffs Sale. In the event that a third party real estate speculator were to bid on the mortgaged property at the Sheriffs Sale and become the successful purchaser, Plaintiff would receive the amount of the in rem judgment from the Sheriff. IV. INTEREST The Mortgage clearly requires that the Defendant shall promptly pay when due the principal and interest due on the outstanding debt. In addition,the Note specifies the rate of interest to be charged until the debt is paid in full or otherwise satisfied. Specifically, interest from 30 days prior to the date of default through the date of the impending Sheriff s sale has been requested. V. TAXES AND INSURANCE If Plaintiff had not advanced monies for taxes and insurance throughout the foreclosure proceeding,Plaintiff would have risked loss of its collateral. If the Property were sold at a tax sale, Plaintiffs interest very well may be divested, and Plaintiff would sustain a complete loss on the outstanding balance due on the loan. If the Property were damaged in a fire,Plaintiff would not be able to obtain insurance proceeds to restore the Property if it did not pay the insurance premiums. Most importantly,the Mortgage specifically provides that the mortgagee may advance the monies for taxes and insurance and charge these payments against the escrow account. Plaintiff is simply seeking to have the Court enforce the terms of the Mortgage. 287693 VI. ATTORNEY'S FEES The Plaintiffs foreclosure fees are very modest. They cover all of the legal work done throughout the course of the foreclosure action to date, including reviewing the Act 6 or Act 91 letters, loan documents, account records, title reports and supporting documents, preparing and reviewing the mortgage foreclosure complaint, filing and service of the complaint, Rule 237.1 Notice, Department of Defense search, entry of judgment, the writ of execution process, lien holder notices, and all of the other legal work that goes into handling the mortgage foreclosure lawsuit. The Mortgage specifically provides for Plaintiff s recovery of its attorney fees. The amount of attorney's fees requested in the Motion to Reassess Damages is in accordance with the loan documents and Pennsylvania law. Pennsylvania Courts have long and repeatedly concluded that a request of five percent of the outstanding principal balance is reasonable and enforceable as an attorney's fee. Robinson v. Loomis, 51 Pa. 78 (1865);First Federal Savings and Loan Association v. Street Road Shopping Center, 68 D&C 2d 751, 755 (1974). In Federal Land Bank of Baltimore v. Fetner,the Superior Court held that an attorney's fee of ten percent of the original mortgage amount is not unconscionable. 410 A.2d 344 (Pa. Super. 1979). The Superior Court cited Fetner in confirming that an attorney's fee of ten percent included in the judgment in mortgage foreclosure action was reasonable. Citicorp v.Morrisville Hampton Real , 662 A.2d 1120 (Pa. Super. 1995). Plaintiff s legal fees are not a percentage but are significantly less than what is permitted by Pennsylvania law. 287693 e VII. COST OF SUIT AND TITLE Pursuant to the terms of the mortgage, Plaintiff is entitled to recover all expenses incurred in the foreclosure action. The amount claimed for the costs of suit and title are the expenses Plaintiff paid to date as a result of the mortgage default. The title report is necessary to determine the record owners of the property, as Pa.R.C.P. 1144 requires all record owners to be named as Defendants in the foreclosure action. It is also necessary to determine whether there are any prior liens to be cleared, so that the Sheriff's sale purchaser acquires clear title to the property. It is necessary to determine if there are IRS liens on the property, whether the Defendants are divorced (which could affect service of the complaint), and numerous other legal issues. The title bringdown is necessary to identify any new liens on the property or new owners between the time of filing and complaint and the writ date. The Freedom of Information Act inquiries and the investigation into Defendants' whereabouts are necessary to effectively attempt personal service of the complaint and notice of sale on the Defendant. The notice of sale and Rule 3129 notice are required by Pa.R.C.P.3129.1 and 3129.2 to notify all lienholders, owners, and interested persons of the Sheriff's sale date, as their interests will be divested by the Sheriff's sale. Accordingly,the modest sums Plaintiff has incurred for the costs of suit and title were necessary pursuant to Pennsylvania law. The amounts were reasonable and actually incurred. The mortgage and Pennsylvania law permit Plaintiff to recover these sums through its foreclosure action. As the foreclosure action is in rem only, Plaintiff recovers its judgment from the sale of the property, not out of the Defendant's pockets. Plaintiff should recover the costs of suit and title in their entirety, which will not cause harm to the Defendants. 287693 6 VIII. PROPERTY INSPECTIONS AND PRESERVATION The terms of the mortgage provide for property inspections and property preservation charges. The lender or its agent may make reasonable inspections of the property pursuant to the terms of the mortgage. When a borrower defaults under the terms of the mortgage, the lender may do, or pay for, whatever is reasonable to protect its interest in the collateral, including property maintenance. Any amounts disbursed by the lender for property inspections and preservation become additional debt of the borrower secured by the mortgage. The lender may charge the borrower for services performed in connection with the default, for the purpose of protecting the lender's interest in the property, including property inspections and valuation costs. When a loan is in default,the lender's risk increases. Mortgage companies typically have a vendor visit the premises to determine if any windows need to be boarded up, if the property is vacant, if the grass needs to be cut, or the snow shoveled. If the property inspection reveals any problems at the mortgaged premises, then the mortgage company may proceed to take whatever steps are necessary to secure the collateral, such as boarding windows, winterizing, removing hazards or debris, etc. The mortgage company generally pays a vendor to handle these tasks, which are referred to in the industry as "property preservation". These services avoid code violations and avoid the property becoming an eyesore in the neighborhood. Property preservation helps maintain property values in the neighborhood. Accordingly, line items included in Motions to Reassess Damages for property inspections and property preservation represent amounts which the mortgage company has paid out of its pocket to preserve its collateral, consistent with the terms of the mortgage contract. 287693 Since the terms of the mortgage provide that such expenses by the mortgage company become part of the borrower's debt secured by the mortgage,those expenses are properly included in the Plaintiff's Motion to Reassess Damages. IX. CONCLUSION Therefore, Plaintiff respectfully submits that if the enforcement of its rights is delayed by legal proceedings, and such delays require the mortgagee to expend additional sums provided for by the Mortgage,then the expenses necessarily become part of the mortgagee's lien and should be included in the judgment. Plaintiff respectfully requests that this Honorable Court grant its Motion'to Reassess Damages. Plaintiff submits that it has acted in good faith in maintaining the Property in accordance with the Mortgage,and has relied on terms of the Mortgage with the understanding that it would recover the monies it expended to protect its collateral. WHEREFORE,Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. Phelan Hallinan, DAT By: Allison F. 2wrman, Esquire Attorn or Plaintiff 287693 t Exhibit "A" 287693 r PHELAN HALLINAN&SCBMIEG,LLP Attorney for Plaintiff Jonathan Lobb,Esq.,Id.No.312174 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia, A 19103 p� � pt` 215-563-7000 WELLS FARGO BANK,N.A. CUMBERLAND COUNTY C) m � VS. COURT OF COMMON PLEAS--ca o m r"n'' - z;VVr TRACY RAMEY CIVIL DIVISION o A/K/A TRACY BOONE -< w o rz -+o A/K/A TRACY L.RAMSEY No.2012-706-CIVII. D° x. O-n zo _= xF3 PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO n 4 Caarm ANSWER AND ASSESSMENT OF DAMAGES -,c TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against.A TRACY BOONE A/K/A TRACY L..RAMSEY,Defendant for swer to Plaintiff's Complaint within 20 days from service thereof and for foreklosure and sale of the mortgaged premises,and assess Plaintiff s damages as follows: As set forth in Complaint $143,863.26 TOTAL $143,863.26 I hereby certify that(1)the Defendant's last known address is 839 NORTH WEST STREET,CARLISLE,PA 17013-1435,and(2)that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date- f -!11//2- ian Lobb,Esq.,-Id.No.312174 ttorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: -� �'�` • PROTHONOTARY 287693 Exhibit "B" 287693 PHELAN HALLINAN, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX##: (215) 563-3459 Phelan Hallinan, LLP Representing Lenders in Pennsylvania and New Jersey April 24,2013 TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY 839 NORTH WEST STREET CARLISLE,PA 17013-1435 RE: WELLS FARGO BANK,N.A. v.TRACY RAMSEY,A/K/A TRACY BOONS,A/K/A TRACY L. RAMSEY Premises Address: 839 NORTH WEST STREET CARLISLE,PA 17013 CUMBERLAND County CCP,No. 2012-706-CIVIL Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is,increasing the amount of the judgment. Please respond to me within 5 days,by 4/30/2013. Should you have further questions or concerns,please do not hesitate to contact me. Otherwise,please be guided accordingly. Very truly yo s; Allison .Zir Hi .,n.,h ` Id. No.309519 Attorney.',` 1'1.ai t f Enclosure 287693 Name and Phelan Hallinan,LLP Address 1617 JFK Boulevard,Suite 1400 tj me C4 3. Mender One Penn Center Plaza Philadelphia.PA 19103 KVM Line Article Number Name of Addressee Street,and Post Office Address Posta a Al C?a St 1 '•*• TRACY RAMSEY $0.46 � 40 a 839 NORTH WEST STREET 2 c CARLISLE PA 17018-1435 e mc' 2 TRACY RAMSEY $0.46 ' 116 ELM STREET �T iuo°o CARLISLE.PA 17013 _ RE:TRACY RAMSEY AWA TRACY BOONE AWA TRACY L.RAMSEY(CUMBERLAND) PHS# 50.90 28769311200 Pgjje 1 of i Taal thuutxrcr TWtl NvmberotPiacet Peemarta,PrajNtuk of Thcfidt dccfiarmka at vat+e nrpryaad at�t34wacttk aad irxaaatrantd repttacd maiE.Ttk max� . Pifto Red by Bondor .. Reedved n Pact Oirw ttetdaiAS Ee+plery-1 for do recowt ctionarwwtxatW*doo mirnb w4or Fxpmu Mal docmew m=wr *0 M!. pace aWioSl tea 4euit Of SS110,000 px aaaurenv.Tiq maximam mdannity paysble an P.xptess 1; ,�'jX. /9 TAe maximam indarc�iry WYabtc it MS,0a0 ferrlyitkred mail.tNM wtiro aplianal iM¢anxnce See Ii90e 5913 andS921 for tixirtnicns otco .q '�� a Form 3877:Facsimile y p 287693 V A Phelan Hallinan, LLP Allison F. Zuckerman, Esq., Id. No.309519 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 allison.zuckerrnan@phelanhallinan.com 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division TRACY RAMSEY CUMBERLAND County A/K/A TRACY BOONE A/K/A TRACY L. No.: 2012-706-CIVIL RAMSEY Defendant CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Reassess Damages, and Brief in Support thereof, were sent to the following individual on the date indicated below. TRACY RAMSEY TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY RAMSEY 839 NORTH WEST STREET 116 ELM STREET CARLISLE, PA 17013-1435 CARLISLE,PA 17013 Phelan Hallinan,LLP DATE: By. Alliso 1 F. Z Ferman, Esquire ATTORNFOR PLAINTIFF 287693 OFTi-itPR QT HOJ�40T1A 4 13 MAY 14 FM V 18 CUMBERLAND COUNTY WELLS FARGO BANK, N.A., PENNSYLVAN A Plaintiff V. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT TRACY RAMSEY A/K/A TRACY 2012-00706 CIVIL TERM BOONE A/K/A TRACY L. RAMSEY, Defendant MORTGAGE FORECLOSURE IN RE: PLAINTIFF'S MOTION TO REASSESS DAMAGES ORDER OF COURT AND NOW, this day of May 2012, upon consideration of Plaintiff's Motion to Reassess Damages, a Rule is issued upon Defendant to show cause, if any, why the relief requested should not be granted. PLAINTIFF shall serve this Rule upon Defendant. Proof of service must be filed prior to the court entertaining a motion to make rule absolute. RULE RETURNABLE twenty (20) days from the date of service by Plaintiff. EG 1W1 R. --V Thomas X. F ia acey C.P.J. Distribution: .XAllison F. Zuckerman, Esq. -,,�Tracy Ramsey A/K/A Tracy Boone A/K/A Tracy L. Ramsey C6 1`9' oz.-,ILL PHELAN HALLINAN,LLP Attorney for Plaintiff C—_ C= -- Allison F.Zuckerman,Esq.,Id.No.309519 m 1617 JFK Boulevard, Suite 1400 rn W" One Penn Center Plaza Philadelphia,PA 19103 -< c n 215-563-7000 D C1 IN THE COURT OF COMMON PLEAS x C_- `• p OF CUMBERLAND COUNTY,PENNSYLVANIA WELLS FARGO BANK,N.A. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L.RAMSEY No.: 2012-706-CIVIL Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P.3129.2(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P.3129.2(c)on each of the persons or parties named,at that address,set forth on the Affidavit and as amended if applicable.A copy of the Certificate of Mailing(Form 3817) and/or Certified Mail Return Receipt stamped by the U.S.Postal Service is atLA *d ereto Exhibit"A". erman q.,Id.No.309519 Attorn Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS#287693 WELLS FARGO BANK,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 1012-706-CIVIL TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L.RAMSEY CUMBERLAND COUNTY Defendant(s) PHS#287693 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK,N.A.,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 839 NORTH WEST STREET, CARLISLE,PA 17013-1435. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained, please so indicate) TRACY RAMSEY 839 NORTH WEST STREET A/K/A TRACY BOONE CARLISLE,PA 17013-1435 A/K/A TRACY L.RAMSEY 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) TRACY RAMSEY 839 NORTH WEST STREET A/K/A TRACY BOONE CARLISLE,PA 17013-1435 A/K/A TRACY L.RAMSEY 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) MAZDA AMERICAN CREDIT P.O.BOX 6508 MESA,AZ 85216-6508 MAZDA AMERICAN CREDIT.C/O JOANN 935 ONE PENN CENTER NEEDLEMAN,ESQUIRE 1617 JFK BOULEVARD PHILADELPHIA,PA 19103 PHS#287693 CLAREMONT NURSING AND 1000 CLAREMONT ROAD REHABILITATION CENTER CARLISLE,PA 17013 CLAREMONT NURSING AND 1700 BENT CREEK BLVD REHABILITATION CENTER,STEVEN M. STE 140 MONTRESSOR,ESQUIRE,LATSHA,DAVIS MECHANICSBURG,PA 1.7050 &MCKENNA,P.C. 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) None. 5, Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained,please indicate) NONE. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address(if address cannot be reasonably ascertained,please indicate) 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 Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 839 NORTH WEST STREET CARLISLE,PA 17013-1435 COMMONWEALTH OF PENNSYLVANIA 6TH FLOOR,STRAWBERRY SQ. BUREAU OF INDIVIDUAL TAXES DEPT 280601 INHERITANCE TAX DIVISION HARRISBURG,PA 17128 DEPARTMENT OF PUBLIC WELFARE,TPL P.O.BOX 8486 CASUALTY UNIT,ESTATE RECOVERY WILLOW OAK BUILDING PROGRAM HARRISBURG,PA 17105 ESTATE OF LEON G.RAMSEY,JR.,C/O 1034 FIFTH AVENUE MARVIN ABRAMS,ESQUIRE SUITE 200 PITTSBURGH,PA 15219 TRACY L.RAMSEY C/O TAYLOR P. 78 WEST POMFRET STREET ANDREWS,ESQUIRE CARLISLE,PA 17013 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 PHS##287693 6 _ a U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA. HARRISBURG,PA 17108-1754 FEDERAL BUILDING I verify that the statements.made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: By. an-. an,LLP Allison F.Zuckerman,Esq.,Jd.No.309519 Attorney for Plaintiff PHS #287693 Name and Phelan 14211inan,LLP Address 1617 JFK 13oukvar4.Suite 1400 cr ay Of Srndcr One Penn Center Plan *q r. Philadelphia,PA 19103 AZK/SFF-06105n013 SALE N Line Article Number Name of Addy Stmet,and Post Office Address Posts 1 CLAREMONT NURSING AND REHABILITATION CENTER WA6 25 X, 1000 CLAREMONT ROAD CARLISLE,PA 17013 T 2 CLAREMONT NURSING AND REHABILITATION CENTER,STEVEN lvL MONTRESSOR.ESQUIRE, 50A6 LATSHA,DAVIS&MCKENNA,P.C, 1700 DENT CREEK BLVD r too STE 140 MECHANICSBURG,PA 17050 RE:TRACY RAMSEY ARIA TRACY BOONE AWA TRACY L.RAMSEY(CUMBERLAI% PITS# S0.92 28769NI 026 PAGE IOFI 45 DAY Taw NUBW or I TOW Nastier 601itm PCstt"0a.Fvr(Name d rtxm Pica brad by Sawa keedwd a Poo Ofr" Rtc6vinj&Vk3w) kw Om mmsuvoien d normtsousu:dmw3cft Uwa Express WAH dom"Km rzoouvx6ft i ptmv*)Wtoabmtlof35Or4OWperooc%xtcm, r*wximmmdamtypy"-Ex Te.m.im..a4ona#y payabtau 525.600 fu KE Td toil,ant with a{Ri9ttt�iruwaaua. ?,I'(ArAS971 Form 387?Facsimile I PHS 287693 Nance and Phelan Hallman,LLP Address 1617 3FK Boulevard,Suite 1400 Of Sender One Penn tenter Ptw Philadolphia�PA 19103 _ _AZKtPAP-06105/2013 SALE L'mc d Posts e AWWNorr1 f Name of Adressm Street sid Post Office Address r j TENANTIOCCUPANT SO.44 839 NOR"WESTSMET t CARLISLE.PA 27613.2435 f 2 w««+ C0 1t 21itU1 1W EA1.321t2FPEgNSYLVAf11ABURFAUOF NDIVIDUAI,TAX2S.IN11ERWANCETAXDINISION 50.44 TFWO01 STRAWBERRY SO. O 1 �_ ry 12Al2RISBURC PA 17125 3 *#sw nF.PARTMf7NTOFPIiRT,IC'%NVIFARk TPI,CAC11AI TYT.Wlr,ESFATER.EC40'%RYPROCRAM $0.d4 0 M W 1, P.O.BOX 63£6 'WILLOWOAKBUILDING FiARRISBURG.PA2710$ tG i 4 w«*► 1 ESTATE OF LEON G.RAMEY.JR.MMARVINABRAMS,ESQUIRE SO.44 1032 FIMI AV1)riU8 SUrM s .r PITr58URGH PA 13214 55 w:«« MAZDA AME'RiCAN CREDIT SO.44 PMLSA AZ 8nI"5w 6 *s«« MAZDA AMERICAN CREDTTCIOJOANNNE EDLEMAN,ESQUIRE SO.44 93S ONE PENN CEVMR �r 1617nXBOUTEVARD PHILADELPHL44 PA 19103 7 ww*+ TRACY LRAMSEYCMTAVIARr.ANOREWS,L5QUBRE 50.44 71 WEST EST POlov"STREET ti CARLISLF_PA 17013 8 #«*« DOMESTIC REIATIONS OF SO.44 CUMBERIANDCOUNTY Iw 13 NORTH HANOVER STREET CARLISLE,rA 171113 9 ew<r C010MONWEAL711OFP&MMYANIA SO, DEFARTTIEWr OE NVELFARE PA.BOX 2575 RAARISRURG,PA 17105 10 +«*+ IN ZRNALREVENUESERVIC£ADVISORV $0.44 1OW11HERTY AVENUE ROOM SOd P177TSBI.MGM PA 15322 11 wwww US.DEPAIY3MENTOFJUSIICE 50.44 US.ATTORNEY FOR THE MIDDLE DISTRICT OF PA MOTRAL BU"tNG , 238 WALNUT STREFI;SUITS220 Po ZOX 11754 RARRLSRURG PA I?108-I'M tt ! At�ctA cY x R n cv .=1�:±atssv�tcxnvt t +? P S4.84 36a6s.311O21an�isP>K �sF;1tliEillo�klt'rlt#1'eltm Toutnle boo( Tatit!lnitbtt orPSIXCS tbs[pastt,TiY{Taaa+e CT 1hetwi6tctetaeooat-Wise is iegored Chill dotrtSnt ssatirttesionoaairefsecsed mil,The rmmmuz sattmmnty palaGh p:�ere i.iaW�Y 5wsdw Rac�iv�dat 9aa0lro. Ttsorivin{Eep)tyreT M d,c anamei>t,ntaa efn lowhTode—mmsmdwZ pimalisd4—oniteeatuutrasoo inArnacass SSA.M#a p.ece su2iod to i limit d37AD.000ptraxutrexc.Themizimm irAtmtiity pwaNe ee Fsptess m"McChawim is$500. 'lilt maximum i+demnity p"Hc is 529,004 for rtysl W msit,mit,itk CltioW hwostc.Sm Demesicc tWMaaaal 89045913 atA S911 fK lmiN6Cnsoteoveei Forth 3877 Facsimile Phelan Hallinan, LLP ui:. '� PRD THONOTAi Justin F. Kobeski, Esq., Id. No.200392 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 1013 KW$ 28 �� One Penn Center Plaza CUMBERLAND COUNTY Philadelphia, PA 19103 PENNSYLVANIA justin.kobeski@phelanhallinan.com 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division VS. CUMBERLAND County TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. No.: 2012-706-CIVIL RAMSEY Defendant CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's May 14, 2013 Rule directing the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individual on the date indicated below. TRACY RAMSEY TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY RAMSEY 839 NORTH WEST STREET 116 ELM STREET CARLISLE, PA 17013-1435 CARLISLE,PA 17013 Phelan Hallinan, L P DATE: Z _ By: Jus m . Kobeski,Esq.,Id.No.200392 Atto ey for Plaintiff 287693 Of," HIP. PROTHONOTARY PHELAN HALLINAN, LLP Attorney for Plaintiff 2013 JUN `5 AM 10� 18 1617 JFK Boulevard, Suite 1400 CUMBLRLAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS VS. CIVIL DIVISION TRACY RAMSEY NO. 2012-706-CIVIL A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY Defendant AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail,return receipt requested,to TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY on FEBRUARY 25, 2013. in accordance with the Order of Court dated JULY 6,2012. The property was posted on MARCH 3, 2013. Publication was advertised in SENTINEL on FEBRUARY 27, 2013 &in THE CUMBERLAND LAW JOURNAL on MARCH 8,2013. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification to authorities. Phelan Hallinan, LLP DATE: oul By: Jonathl0fofib, Esq., Id. No.312174 Attorney for Plaintiff WELLS FARGO BANK, N.A., Plaintiff V. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY, Defendant NO. 2012-706 CIVIL TERM IN RE: MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT ORDER OF COURT I AND NOW, this ( of July, 2012, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of C6urt, it is ordered that service of the Complaint in this case upon the Defendant, Tracy Ramsey may be made (1) by first- i class and certified mail at the last known address, 839 North West Street, Carlisle, Pennsylvania 17013, service to be deemed complete upon mailing; (2) by posting the Complaint on the most public portion of the property located at 839 North West Street, Carlisle, Pennsylvania 17013; and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. SUBSEQUENT papers may be served by first-class mail to Defendant at the aforesaid North West Street address with service to be deemed complete upon mailing. COUNSEL FOR PLAINTIFF is hereby DIRECTED to file a certificate of service with the Prothonotary's office to ensure compliance with this Court Order. t i BY THE COURT, Thomas cey, C.P.J. Distribution: Matthew G. Brushwood, Esq. Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 w i/ Tracy Ramsey c 839 North West Street -Al Carlisle, PA 17013 Tracy Ramsey C„ 116 Elm Street Carlisle, PA 17013 4pp;es lica` ew Y E , Name and PHELAN HALLINAN&SCHMIEG ;n r Address One Penn Center at Suburban,Suite 1400 of Sender Philadelphia,PA 19103 Line Article i Name of Addressee,Street,and.Post Office Address Postage .- Number 1 ; RACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L.RAMSEY 1639 NORTH WEST STREET �ARLISLE,PA 1.7013-1435 2 **** [ _ i 5 �< 6 **** 7 **** �l 9 **** 10 **** 11 **"* 12 :.TRACY RAMSEY A/K/A TRACY BOONE A/KIA TRACY L.RAMSEY PHS#287693 Total Number of Total Number of Pieces Postmaster,Per(Name of.Recciving [ Pieces Listed by Sender Received at Post Office Employee) 11 LXH- *NOTICE OF SALE: CERTIFICATE OF MAILING* CODE: 1020 ' 7178 2417 6099 0127 2043 LXH/287693 1020 TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L.RAMSEY 839 NORTH WEST STREET CARLISLE, PA 17013-1435 --fold here(regular) --fold here(60) --fold here(regular) USPS.com® - Track& Confirm Page 1 of 1 English Customer Service USPS Mobile Register/Sign In aUSPSCOKSearch t1SPS.com or Track Packages Quick Tools Ship a Package Send Mail Manage Your Mail Shop Business Solutions Track & Confirm i>C�r is iAt.iiPDA*:5 PRINTDETAILS YOUR LABEL NUMBER SERVICE STATUS OF YOUR ITEM DATE&TIME LOCATION FEATURES 71782417609901272043 First-Class Mail® Delivered March 1,2013,9:00 am PHILADELPHIA,PA 19103 Expected Delivery By: March 2,2013 Certified Mail" Notice Left(No February 28,2013,11:50 am PHILADELPHIA,PA 19103 Authorized Recipient '.Available) Arrival at Unit !.February 28,2013,10:59 am PHILADELPHIA,PA 19104 Depart USPS Sort February 28,2013 PHILADELPHIA,PA 19176 Facility Processed at USPS February 28,2013,3:45 am PHILADELPHIA,PA 19176 Origin Sort Facility Accepted at USPS February 28,2013,2:30 am PHILADELPHIA,PA 19103 Origin Sort Facility l Electronic Shipping Info February 25,2013 Received Check on Another Item What's your label(or receipt)number? Find LEGAL ON USPS.COM ON ABOUT,USPS.COM OTHER USPS SITES Privacy Policy> Government Services; About USPS Home) Business Customer Gateway: Terms of Use) Buy Stamps&Shop, Newsroom, Postal Inspectors, FOIA, Print a Label with Postage, N1aii Service Updates,' Inspector General) No PEAR Act EEO Data, Customer Service, Forms&Publications, Postal Explorer> Delivering Solutions to the,Les!Mile) Careers� Site Index, Copyright-2013 USPS.All Rights Reserved. https://tools.usps.com/go/TrackConfirmAction.action?tLabels=71782417609901272043 5/30/2013 AFFIDA� IT OF SERVICE PLAINT'IF'F CUMBERLAND COUNTY WELLS FARGO BANK,N.A. ,. PHS#287693 DEFENDANT SERVICE TEAM/st) TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. COURT NO.:2012-706-CIVIL RAMSEY SERVE TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY TYPE OF ACTION L.RAMSEY AT: XX Notice of Sheriffs Sale 839 NORTH WEST STREET SALE DATE:06/05/2013 CARLISLE,PA 17013-1435 ****PLEASE POST THE PROPERTY*** **PLEASE POST PROPERTY IN ACCORDANCE WITH THE COURT ORDER** SERVED Served and made known to aRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY,Defendant on the day of 20 at ,o'clock M.,at 839 NORTH WEST STREET,CARLISLE,PA 17013-1 435,in the manner described below: Defendant personally served. Adult family member with whom Defendant(s)reside(s). Relationship is _Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. XX Other: POSTED THE PROPERTY Description: Age Height Weight Race Sex Other I, +?I ( - f ,a competent adult,hereby verify that I personally posted the property with a true and correct copy of the&otice of Sheriff's Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn/falsification to authorities. DATE: /3 NAME: V PRINTED NAME: TITLE: G )Ce-Xr e tT V e s, NOT SERVED On the. day of 20—,at o'clock_.M.,I, a competent adult hereby state that a endant because: Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) _No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T.Phelan,Esq.,Id.No.32227 Francis S.Hallman,Esq.,Id.No.62695 Daniel G.Schmieb,Esq.,Id.No.62205 Michele M.Bradford,Esq.,Id.No.69849 Judith T.Romano,Esq.,Id.No.58745 Jenine R.Davey,Esq.,Id.No.87077 Lauren R.Tabas,Esq.,Id.No.93337 Jay B.Jones,Esq.,Id.No.86657 Andrew L.Spivack,Esq.,Id.No.84439 Chiisovalante P.Fliakos,Esq.,Id.No.94620 Courtenay R.Dunn,Esq.,Id.No.206779 Allison F.Zuckerman,Esq.,Id.No.309519 pN� • 216--( cO PROOF OF PUBLICATION State of Pennsylvania,County of Cumberland Tackie Cox,Sales Director, 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): February 27, 2013 COPY OF NOTICE OF PUBLICATION •-�4 NOTICE OF SHERIFF'S SALE IN THE COURT OF COMMON PLEAS i OF CUMBERLAND COUNTY,PENNSYLVANIA F NO.2012-706-CIVIL �JJ Affiant further deposes that he/she is not WELLS FARGO BANK,N.A. t' interested in the subject matter of the TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L.RAMSEY l' aforesaid notice or advertisement,and that t NOTICE TO:TRACY RAMSEY.A/r/A TRACY BOONE A/K/A TRACY L. all allegations in the foregoing statement as 4 RAMSEY NOTICE�OF SHERI,FF'S SALE OF REAL PROPERTY to time,place and character of publication Being Premises:839 NORTH WEST STREET,CARLISLE,PA 17013-1435 ( a ue. Being in CARLISLE BOROUGH,County of CUMBERLAND, 1 Commonwealth of Pennsylvania,06-19-1643-243. 1 Improvements consist of residential property. Sold as the property of TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L.RAMSEY I Your house(real estate)at 839 NORTH WEST STREET,CARLISLE,PA j 17013-1435 is scheduled to be sold at the Sheriffs Sale on 06/05/2013 at r 10:00 AM,at the CUMBERLAND County Courthouse,1 Courthouse ( Square,Carlisle,PA 17013,to enforce the Court Judgment of$143,863.26 obtained by,WELLS FARGO BANK,N.A.(the mortgagee),against the Sworn to and subscrib d before me this above premises. 1AAV" PHELAN HALLINAN,LLP Attorney for Plaintiff t �.�/ ✓✓✓ 7 v' Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENOORN Notary Public CARLISLE BOROUGH,CUMBERLAND CNTY My Commission Expires Jan 27,2014 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 March 8, 2013 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. c 'sa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 8 day of March, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My commission Expires Apr 28,2014 a CUMBERLAND LAW JOURNAL NOTICE OF SHERIFF'S SALE In the Court of Common Pleas of Cumberland County, Pennsylvania NO. 2012-706-CIVIL WELLS FARGO BANK, N.A. vs. TRACY RAMSEY a/k/a TRACY BOONE a/k/a TRACY L. RAMSEY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY NOTICE TO:TRACY RAMSEY a/k/a TRACY BOONE a/k/a TRACY L. RAMSEY Being Premises:839 NORTH WEST STREET,CARLISLE,PA 17013-1435. Being in CARLISLE BOROUGH, County of CUMBERLAND, Com- monwealth of Pennsylvania, 06-19- 1643-243. Improvements consist of residen- tial property. Sold as the property of TRACY RAMSEY a/k/a TRACY BOONE a/k/a TRACY L. RAMSEY. Your house (real estate) at 839 NORTH WEST STREET, CARLISLE, PA 17013-1435 is scheduled to be sold at the Sheriff's Sale on June 5, 2013 at 10:00 A.M.,at the CUMBER- LAND County Courthouse, 1 Court- house Square, Carlisle, PA 17013, to enforce the Court Judgment of $143,863.26 obtained by, WELLS FARGO BANK,N.A. (the mortgagee), against the above premises. PHELAN HALLINAN,LLP Attorneys for Plaintiff Mar. 8 9 Phelan Hallinan, LLP poo Allison F. Zuckerman, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 4111EIqEY FOR PLAINTIFF One Penn Center Plaza Ufi' COUNTY Philadelphia, PA 19103 allison.zuckerman@phelanhallinan.com 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division vs. CUMBERLAND County TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. No.: 2012-706-CIVIL RAMSEY Defendant MOTION TO MAKE RULE ABSOLUTE WELLS FARGO BANK, N.A., by and through its attorney, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: 1. A Motion to Reassess Damages was filed with the Court on May 2, 2013. 2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on April 1 24, 2013 and requested the Defendant's Concurrence. Plaintiff did not receive any response from the Defendant. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and certificate of mailing are attached hereto, made part hereof, and marked as Exhibit A. 3. A Rule was issued by the Honorable Thomas A. Placey on or about May 14, 2013 directing the Defendant to show cause by June 11, 2013 why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit B. 4. The Rule to Show Cause was timely served upon all parties on May 24, 20 1 3) in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit C. 287693 5. Defendant failed to respond or otherwise plead by the Rule Returnable date of June 11, 2013. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. ZA Hallman, DATE: B F. Zuckerm sq., Id.No.309519 for PI ' iff 287693 Exhibit "A" 287693 PHELAN HALLINAN, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA.19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallman, LLP Representing Lenders in Pennsylvania and New Jersey April 24,2013 TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY 839 NORTH WEST STREET CARLISLE,PA 17013-1435 RE: WELLS FARGO BANK,N.A. v. TRACY RAMSEY,A/K/A TRACY BOONE, A/K/A TRACY L. RAMSEY Premises Address: 839 NORTH WEST STREET CARLISLE,PA 17013 CUMBERLAND County CCP,No. 2012-706-CIVIL Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, increasing the amount of the judgment. Please respond to me within 5 days,by 4/30/2013. Should you have further questions or concerns,please do not hesitate to contact me. Otherwise,please be guided accordingly. Very truly yti s' Allison If: Zuc': rn -n.,'h ;,Id.No.309519 Attorney;'. Enclosure 287693 s i Name and Phelan Hallinan,LEI' o Address 1617 X Boulevard,Suite 2400 Of Sender One Penn Center Plaza c Philadelphia,PA 19103 KVM. i Line Article Number Name of Addressee Street,and Post Office Address Postage ,i 0� 3 ••*• TRACY RAMSEY SO.46 839 NORTH WEST STREET CARLISLEi PA 17023-1435: F 2 *** TRACY RAMSEY 50.46 A NO 11.6 ELM STREET � ntoo CARLISLE PA 27013 yq• RE:TRACY RAMSEY A/K/A TRACY BOONE AWA TRACY L.RAMSEY(CUMBERLAND) PHS k 50.90 287693!1200 Page i of 1 Tani'}7umbes of Toiai Nnmberof Piece lUstmasta,Ptr{Nanicar not fun dcCLvuias of slue is rcgoncdan atS earxxia sad iatunasionni rtynxectd snail.T#re may. S,. Pitces Lived lry Sander. Resivtd w Past 00kc Receiving Employs) for the reconwvction of tumo'sViable domeerds under Expem Mail doctanol rxansintction im i pile Z bjoet to tint*f$.W0,W0 per oecs« .,.The ma imnm tnde ity payablt oo EYpross 1 The matimnra indenwity payable is$2S,000 for ngirceed snail,acrd with optianal inawarrte,Ss '��'' 'ire '9905913 am 5921 for ii'mitations ofco Q Form 3877 Facsimi)e t - 1 i t 287693 Exhibit "B" 287693 +JiM !f;lrc . H13 MAY 14 PH 4^ f U WELLS FARGO BANK, N.N,MDERLAND CO ftIT`y{ Plaintiff- PENNSYLVANIA ... .... . _.. ..... V. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT TRACY RAMSEY A/K/A TRACY 2012-00706 CIVIL TERM BOONE A/K/A TRACY L. RAMSEY, Defendant MORTGAGE FORECLOSURE IN RE: PLAINTIFF'S MOTION TO REASSESS DAMAGES ORDER OF COURT AND NOW, this day of May 2012, upon consideration.of Plaintiff's Motion to Reassess Damages, a Rule is issued upon Defendant to show cause, if any, why the relief requested should not be granted. PLAINTIFF shall serve this Rule upon Defendant. Proof of service must be filed prior to the court entertaining a motion to make rule absolute. RULE RETURNABLE twenty (20) days from the date of service by Plaintiff. B Thomas lacey C.P.J. Distribution: Allison F. Zuckerman, Esq. Tracy Ramsey A/K/A Tracy Boone A/K/A Tracy L. Ramsey Exhibit "C" t Phelan Hallinan, LLP Justin F. Kobeski, Esq., Id. No. ' ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 140.1 " One Penn Center Plaza 1 °'i F t C011N Philadelphia,PA 19103l � l ' justill.kobeski@phelanhallinaii.com 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division vs. CUMBERLAND County TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L, No.: 2012-706-CIVIL RAMSEY Defendant CERTtFIC.ATION OF SERVICE I hereby certify that a true and correct copy of the Court's May 14, 2013 Rule directing the.Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individual on the date indicated below. TRACY RAMSEY TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. A/K/A"TRACY BOONE A/K/A TRACY L. RAMSEY RAMSEY 839 NORTH WEST STREET 116 ELM STREET CARLISLE,PA 17013-1435 CARLISLE, PA 17013 Phelan Hallinan,L' l? DATE;.. �_ j Azlt�t__ By' at�s 111,y"�Kobeski, Esq.,Id.No.200392 ,�tto;ley for Plaintiff 287693 Phelan Hallinan, LLP Allison F. Zuckerman, Esq., Id. No.309519 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 allison.zuckerman @phelanhallinan.com 215-563-7000 WELLS FARGO BANK, N.A. Court of Common Pleas Plaintiff Civil Division vs. CUMBERLAND County TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. No.: 2012-706-CIVIL RAMSEY Defendant CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of Plaintiffs Motion to Make Rule Absolute was served upon the following individual on the date indicated below. TRACY RAMSEY TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY RAMSEY 839 NORTH WEST STREET 116 ELM STREET CARLISLE, PA 1701.3-1435 CARLISLE, PA 17013 Phelan Hal ' , LLP DATE: By. ison . Z erman, Esq., Id. No.309519 Attorney or Plaintiff 287693 4(2 G IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division vs. CUMBERLAND County TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. No.: 2012-706-CIVIL RAMSEY Defendant ORDER AND NOW, this M"I day of%7tLW— , 2013, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendant shall be and is hereby made absolute and Plaintiff's Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance $138,597.14 Interest Through May 1, 2013 $13,339.92 Late Charges $1.62.1.6 Legal fees $1,800.00 Cost of Suit and Title $2,227.12 Property Inspections $295.00 Mortgage Insurance Premium/Private Mortgage Insurance $931.51 Mortgage Insurance Premium to be paid $97.40 Escrow to be paid $1,346.14 287693 Escrow Deficit $4,253.07 TOTAL $163,049.46 Plus interest at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. T E COURT: J. omas A.Plaosy Common Pleas Judge C-- M� �D Cn r' =t= CD y�CI, _c 287693 FILED-OFFICE OF THE PROTHONOTARY 2o;3 JUL 18 Ali fl: 50 CU PEA SYL COUNTY VAN A PHELAN HALLINAN, LLP Joseph P. Schalk, Esq., Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 Attorney for Plaintiff WELLS FARGO BANK,N.A. 3476 STATEVIEW BOULEVARD Court of Common Pleas FORT MILL, SC 29715 Civil Division Plaintiff Term V. No.2012-706-Civil TRACY RAMSEY A/K/A TRACY BOONE Cumberland County A/K/A TRACY L. RAMSEY 839 NORTH WEST STREET CARLISLE,PA 17013-1435 Defendant MOTION TO LIFT CONCILIATION STAY Plaintiff, Wells Fargo Bank, N.A. Successor (hereinafter "Plaintiff'), by its attorney, Joseph P. Schalk, Esquire, hereby files the within Motion to Lift Conciliation Stay and in support thereof avers as follows: 1. On February 6, 2012, Plaintiff filed a Complaint in Mortgage Foreclosure against Defendants for their failure to make monthly payments of principal and interest upon their mortgage due August 1, 2011., and each month thereafter. A true and correct copy of the Complaint is attached hereto, made part hereof and marked as Exhibit A. 2. On September 18, 2012, Plaintiff completed service on Defendant of the Complaint in Mortgage Foreclosure along with service of the Cumberland County Residential 287693 Mortgage Foreclosure Diversion Program Notice via posting to the property. A true and correct copy of the Affidavit of Service is attached hereto, made part hereof and marked as Exhibit B. 3. Service was also completed by publication as provided by Pa. R.C.P. Rule 430(b)(1)in The Sentinel on September 12,2012 and Cumberland Law Journal on September 21,2012. Proofs of the said publications made part hereof and marked as Exhibit C. 4. Pursuant to the Cumberland County Administrative Order February 28, 2012, which created the Cumberland County Residential Mortgage Foreclosure Diversion Program, the Foreclosure action is stayed for sixty (60) days from the date of service. 5. Within 60 days after service of the complaint, the Defendant may opt into the program by filing a Request for Conciliation Conference with the Court. Upon the filing of the request, the Court will schedule a Conciliation Conference. The program provides that Defendant must contact MidPenn Legal Services within the first twenty (20) days of receipt of notice if not represented by counsel. 6. If more than sixty (60) days has elapsed since the service of Notice of Residential Mortgage Foreclosure Diversion Program and the Defendant has not opted to participate in the Diversion Program Plaintiff may petition the Court to lift the stay and remove the case from the Diversion Program. 7. Defendant failed to opt into the Cumberland County Residential Mortgage Foreclosure Diversion Program within sixty(60) days of service. 8. Due to Defendant's failure to opt in to the program, Plaintiff inadvertently proceeded with the entry of judgment prior to lifting the stay imposed by the Diversion Program on November 13, 2012. 9. Defendant received service of the Complaint, had an opportunity to enter the 287693 Diversion Program and had an opportunity to defend the foreclosure action, but opted instead to take no action whatsoever with respect to this matter. 10. Since Defendant opted not to participate in the Diversion Program or litigated the instant foreclosure action, it is appropriate for the stay to be lifted nunc pro tunc and the judgment confirmed. WHEREFORE, Plaintiff respectfully requests that this matter be removed from the Cumberland.County Residential Mortgage Foreclosure Diversion Program, the stay be lifted nunc pro tunc, and the default judgment entered November 13, 2012 is hereby confirmed. Respectfully submitted, PHELAN HALLINAN, LLP Date: 1 4 �'S BY:+sh v`- chalk, Esquire r Plaintiff 287693 Exhibit A FILED-OFFICE OF THE PROTHONOTARY 2012 FEB -6 AM 9: 17 CUMBERLAND COUNTY PtNNSYEVANlA PHELAN HALLINAN&SCB IIEG,LLP Robert W.Cusick, Esq., Id.No.80193 1617 JFK Boulevard,Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 287693 WELLS FARGO BAND,N.A. 3476 STATEVIEW BOULEVARD COURT OF COMMON PLEAS FORT MILL, SC 29715 CIVIL DIVISION Plaintiff TERM TRACY RAMSEY NO. A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY CUMBERLAND COUNTY 839 NORTH WEST STREET CARLISLE,PA 17013-1435 Defendant .QVIL A.CT ON -LAW CO`1?[PWW INWORTGAGE FO,RE10,OSURE ' 0. to-b£ co'p`y CoTfe ON File M: 287693 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'PR.OVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT-AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED TEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOC[ATION. CUMBERLAND CO,UNTY'COURTHOUSE 2'LIBERTY AVENUE CARLISLE,PA 17013 (717).249-3166 {800)990-9108 File#: 287603 i. Plaintiff is WELLS FARGO BANK,N.A. 3476 STATEVIEW°BOULEVARD FORT MILL, SC 2971.5 2,. The namc(s) and last known address(es) of the.Defendant(s) are;; TRACY RAMSEY A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY 839 NORTH WEST.STREET CARLISLE;PA 17013-1435 who is/are the mortgagor(s) and/or real owners) of the property hereinafter described. 3 On 04/15/2008 TRACY RAMSEY and.LEON G. RAMSEY, JR made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS A NOMINEE FOR LEND AMERICA, ANEW EW YORK CORPORATION which mortgage is recorded in the Office of the Recorder of'CUMBERLAND County, in Mortgage Instrument No. 2008245.1.4. By Assignment of Mortgage recorded 12104%2009 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 2009.40444. Said Mortgage was modified as set forth in the modification agreement recorded September 10; 2010, in-Instrument No. 2`01025272. The•mortgage and.assignment(s), if any, are matters of.public record and are incorporated herein by reference in accordance with Pa.R.C.P: 1019(g); which Rule'releves the Plaintiff from its obligations to attach, documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as.attached. Filew; .287693 5,, The mortgage is in.default because monthly payments of principal and interest upon said .mortgage.due 08/01/2011 and each month thereafter are due and unpaid, and by the terms Of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible'forthwith. 6;. The following amounts are due on the mortgage as of 12/28/2011: Principal Balance $13.8,597.1.4 Interest $3,570.05 through 12/28/20.11 Late Charges $162.16 Property Inspections $100.00 Escrow Deficit $1.4 33.91. TOTAL $143,863.26 7; Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right,if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose,as set forth in Act 6 of 1974 and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon. File#: 281693 9r LEON G. RAMSEY, JR was a co-record owner of the mortgaged premises as a tenant by the entirety. By virtue of LEON G:RAMSEY, JR's death on or about 06/1.1/2011, his ownership interest was automatically vested in the surviving tenant by the entirety. 10. Plaintiff hereby releases'LEON G.RAMSEY, JR,from liability for the debt secured by the mortgage: WHEREFORE,Plaintiff demands an in rem judgment against the.Defendant(s) in the sum of $143;863.26, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to.attorney fees and costs,.and for the foreclosure and sale of the mortgaged.property. P:NFL IhIA '& SC;HMIEG, LLF f ... By Rob f: ` us:7ck,,Esqurre Attomey for Plaintiff File#: 287693 LEGAL DESCRIPTION ALL THAT CERTAIN LOT OR GROUND SITUATE IN THE BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, .BOUNDED AND DESCRIBED AS FOLLOWS: ON THE WEST BY NORTH WEST STREET; ON THE NORTH'BY LOT NO. I., BLOCK 21 ON THE HEREINAFTER MENTIONED PLAN OF LOTS ON THE EAST BY A 16 FOOT WIDE ALLEY; AND ON THE SOUTH BY PROPERTY NOR OR FORMERLY OF MRS. SUSAN.MORRISON; CONTAINING 25 FEET IN FRONT ON SAID WEST NORTH STREET AND EXTENDING IN DEPTH AN EVEN WIDTH 190 FEET TO THE AFORESAID :ALLEY, AND BEING LOT NO. 2, BLOCK 21, IN A PLAN OF LOTS LAID OUT BY THE CARLISLE LAND AND IMPROVEMENT COMPANY, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN MIS C. BOOK 11, PAGE.572. SAID LOT OF GROUND HAS THEREON ERECTED A TWO AND ONEHALF STORY FRAME DWELLING HOUSE AND NECESSARY OUTBUILDINGS KNOWN AS 839 NORTH WEST STREET. PROPERTY.ADDRESS: 839 NORTH WEST STREET, CARLISLE,PA 17013-1435 PARCEL#06-19-1643-243. File#: 287693 VERMEICATIO.N Ismael Hernandez, hereby states thatVshe is Vice President Loan :Documentation of WELLS:FARGO BANK,N.A.,plaintiff or mortgage servicing agent for plaintiff in this:matter,thatashe is authorized to make this Verification; and.verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best df `'iS I%t information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Fl Name: Ismael Hernandez DATE: `' . Title: Vice President Loan Documentation File#287693 Name:'RAMSEY AND BOONE 032-PA-V3 Exhibit B AFFIDAVIT OF SERVICE— CUMBERLAND MYH 1'LAINTIFI+ COUNTY C.t.11vi— RLAND I WELLS FARGO BANK,N.A> COURT NO. 2012-706,CIVTI, ' DEI�CIVUANT TRACY RAMSEY A/K/A TRACY BOONE A/K/A TYPE OF ACTION TRACY L. RAMSEY X.X Mortgage Foreclosure Eviction SER.V.E.AT: XX Civil Action 839 NORTH WEST STREET, CARLISLE,I'A 17013-1435 : Complaint on Promissory Note ***PLEASE POST THE PROPERTY*** ***1N ACCORDANCE WITH THE***** ***.ATTACHED:CO,URTO TER******.. - - &rved j,_ Posted and made known TRACY RAMSEY A/K/A TP-ACY BOONE A/K/A TRACY L. RAMSEY, Defendant on the -J&4&` `_day S l'fM'I6iER �2tSA atf3:pA d"c16cR M Esic1i39 NORTH WEST STREET,CARLISLE,PA 17013-1435,in the manner described below: �efendant,person171;l,y served;.; �',4dhit:fanily meu�bcr v�ith:u?liom Defcndant(s)reside(s), Relationship is Adult in charge of Defendan't's residence who refused to give name/relationship.. Manager/Clerk of.place-of.lodging in which Defendant(s)reside(s). Agent or.person in charge of Defendant's office or usual place of business. an office of said defendant company. Description: Age Height Weight Race_ Sex. Other Rlomild Moll 1, competent adult,being duly sworn according-[o law,depose and State that 1 personally posted a true and correct co)y ofthcComplaint in Mortgage Foreclosure issued in the caplion on tic date and lhc,addtecs mdicatcd above.(understand that this statement is made subject to the penalties of 18 Pa.C,S.Sec.4904 rela air W11, rn,falsi 1166 U luthor( DATE: Q � �:I:.� `NA(E K _ r. �.. Ronald MOIL PRINTED NAMEi:. TITLE; Pl"OCCSS Serves NOT.SGRYlsI). On.the_day�f_ _ __—..20_,at o'clock_.M.,Defendant NOT POUND because: Vacant _Does Not Exist Movcd _Does Not Reside(Not Vacant) _.No Answer on__. -Pt Service Refused Other. PHS#257693 Exhibit C 287693 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 Sept rnber,21, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. �Lh,3/Mar'rie:Coyne,E rtor SWORN TO AND SUBSCRIBED before me this 21 da, of f September, 201.2 r Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 26,2014 2 T 7��3 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN property or other rights important MORTGAGE FORECLOSURE to you. YOU SHOULD TAKE THIS NO- In the Court of Common Pleas of TICE TO YOUR LAWYER AT ONCE. Cumberland County,Pennsylvania IF YOU DO NOT HAVE A LAWYER, Civil Action—Law GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE NO. 2012-706-CIVIL CAN PROVIDE YOU WITH INFORMA- TION ABOUT HIRING A LAWYER. WELLS FARGO BANK,N.A. IF YOU CANNOT AFFORD TO vs. HIRE A LAWYER,THIS OFFICE MAY TRACY RAMSEY a/k/a TRACY BE ABLE TO PROVIDE YOU WITH BOONE a/k/a TRACY L.RAMSEY INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES NOTICE TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. TO TRACY RAMSEY a/k/a TRA- CUMBERLAND COUNTY CY BOONE a/k/a TRACY L. LAWYER REFERRAL SERVICE RAMSEY: Cumberland County You are hereby notified that on Bar Association February 6, 2012, Plaintiff, WELLS 32 South Bedford Street FARGO BANK,N.A.,filed a Mortgage Carlisle,PA 17013 Foreclosure Complaint endorsed with (800)990-9108 a Notice to Defend, against you in Sept. 21 the Court of Common Pleas of CUM- BERLAND County, Pennsylvania, docketed to No. 2012-706-CIVIL. Wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 839 NORTH WEST STREET,CARLISLE,PA 17013 whereupon your property would be sold by the Sheriff of CUMBERLAND County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of this publication or a Judgment will be entered against you. 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 6 ' Zg 76`I 3 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland ]ackie Cox, Sales Director,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): September 12, 2012 COPY OF NOTICE OF PUBLICATION TICE OF/LOTION 1N maRTOACIR FOR1=OL O aUne', Gt�MMOJi PLI qS 01"CUMBERLANts CQUNTY,pe N9fLVAt IA 1 clVil.Iu�irypN;:LAW" >. CtURTOF.6oMMo1i t?LEr1S Affiant further deposes that he/she is not• bc��v1: c�V(Laivtslol5fa interested in the subject matter of the CUMSERLANri cougTv aforesaid notice or advertisement,and that Nc3:2otxaa:c)vJt all allegations in the foregoing statement as nlaerG to time, place and character of publication POOPEAJJ tATRACY4 RAMSSY; are true. 9tYI1. 1Z.°platgCfi,Wr±U PAROO ib o uraB.AnNim1on*A,J a antl.■gq�nglyol In C 4tl it M00291110 Foreaooura pioea a!CUMBitRLt�Nt7.C.oyti(y t�Yd6.ru1V14 Wherafftptpn6�`aiaksi a{otaicl oYecn+[hettlorly3tpaae�NtgQtiit �T�tW1;s7"St`RE'"E7`;vfiF#ltsl:f±,,PA47ot�+vhrr8u'PutSyauLprdportYVraukltiasold , Ciivat�r, th �va rafarrneoil:C6mJ>Ntni on'0.6eforo 10,doya f�am'Ihb dYta of liiti r et3tgtlag'fifp�tybu.'.:. 1WoTtoP ,;•,� �, pRaar«rras, Sworn to gad sulascz1l eel bcfoxe me this �m atif (ifla nPliypPbyatlarrfnyand`fileyaelydfafot( aaardbjeabopa ou fsNilto ito ao thd.opa may �oo�cifM1jtfflBtaut you 11 a f dp ent 2-+� u1fui(4srnol ac ter 0) '01101'f eques3ed.Iay.the plamti Yoli BY,I +tsorllYat J lOYou OIJdURWATONCE $ IFY6uO'poNo.y.TOfAyW(�AlAwyt dT0fTOORE H JN'ORMX15ta . E ALAMgA.THIS 0010f MAYBEABLET.O PROVIDE YOU.WJTJJ 1 ES7NA7MAY'OFFEIY;LEGAk iE ftVECE$?1`OELItfIOCEPERAONSIT°A 1 CUMBERLAND 4WN'TK LiAWYEFl REFERgA SEltl/(C6'. Notary Public UMB1 lTL4Plt)CbUNTY AARA9VI7C1pT10N 8$8bU7tiBEFl60itD:ST GARL(SLE,.tA,fAt)t �; eo0�t3s0;9fGS r. . My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH,CUMBERLAND CNTY joy Commission Expires Jan 27,2014 Z- x 76 �� PHELAN HALLINAN, LLP Joseph P. Schalk, Esq., Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000° Attorney for Plaintiff WELLS FARGO BANK, N.A. Court of Common Pleas 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Civil Division Plaintiff Term V. No. 2012-706-Civil TRACY RAMSEY Cumberland County A/K/A TRACY BOONE A/K/A TRACY L. RAMSEY 839 NORTH WEST STREET CARLISLE,PA 17013-1435 Defendant CERTIFICATION OF SERVICE I certify that a true and correct copy of Plaintiff's Motion to Lift Conciliation Stay and proposed Order were sent via first class mail to the person listed below on the date indicated: TRACY RAMSEY . 839 NORTH WEST STREET CARLISLE, PA 17013-1435 Date: � By, ose h Schalk, Esquire Atto ney for Plaintiff 287693 IN THE COURT OF COMMON PLEAS CUMBERLAND,COUNTY, PENNSYLVANIA WELLS FARGO BANK,N.A. 3476 STATEVIEW BOULEVARD Court of Common Pleas FORT MILL, SC 29715 Civil Division Plaintiff Term V. No.2012-706-Civil TRACY RAMSEY A/K/A TRACY BOONE Cumberland County A/K/A TRACY L. RAMSEY 839 NORTH WEST STREET CARLISLE,PA 17013-1435 Defendant ORDER AND NOW, this Z2 i day of go', , 2013, upon consideration of Plaintiff's Motion to Lift Conciliation Stay in the above captioned matter, it is hereby ORDERED and DECREED that.this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program; it is further ORDERED and DECREED that the automatic Stay is lifted and Plaintiff may proceed with its Mortgage Foreclosure Action. BY THE COURT: J. C-- a m rn C r'l� 3 � r M CD� C--) co O D,C CJU �fTt �a 287693 t CC: Tracy Ramsey Joseph P. Schalk, Esq., Id. No. 91656 Attorney for Plaintiff PHELAN HALLINAN, LLP Joseph P. Schalk, Esq., Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 TRACY RAMSEY 839 NORTH WEST STREET CARLISLE, PA 17013-1435 287693 ��U��«� ��U�� CUMBERLAND ��^�� SHERIFF'S" ~� ��" " ""�°� ��" ~��°"°"��~�"��^��"�� COUNTY " Ronny RAnderson Sheriff � ' '''� ��Tu' ` ' ..U1V�r^�y Jody � �m�h �— 11a �� /� ��'" Chief Deputy � � °''' °� � 7 Richard VVStewart � 3»��» �p�m`T�S�R�p ~' 'v DCO �y Wells Fargo Bank, NA vs. Case Number Tracy Ramsey a/WoTracy Bnone, A/K/ATnony L Ramsey | 2012'706 SHERIFF'S RETURN OF SERVICE 04/03/2013 09:48 AM -Deputy Noah Cline, being duly sworn according to law, states service was performed by posting e true copy of the requested Real Estate Writ, Notice and Description, and Go|a Handbill in the above titled ootion, upon the property located at 839 North VVaat Stvaet, Carlisle Bonough, Codie|e, PA 17O13. Cumberland County. 04/03/2013 09:48 AM - Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Deocription, in the above titled action, upon the within named Defendant, to wit: Tracy Ramsey a/k/a Tracy 800no, AJK/Y\Tracy L Ramoay, pursuant to Order ofCourt by"Posting"the premises located at 839 North West Gtnaed, Carlisle Bovough, Cadin|e, R4 17013. Cumberland County with a true and correct copy according holaw. 06/04/2013 As directed by Joseph Schalk, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/10/2013 07/08/2013 As directed by Joseph Schalk, Attorney for the Plaintiff, Sheriffs Sale Continued to 9/4/2013 09/05/2013 Ronny R.Anderson, Ghariff, being duly sworn according to(nw, states that after due and legal notice had been given according to |ow, he exposed the within described premises at public venue or outcry atthe Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on September 04, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Joseph Scho|k, on behalf ofWells Fargo Bank, N.A.. being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $940.86 SO ANSWERS, November 20. 2O13 RbNtn R ANDERSON, SHERIFF � �l� �~�^ C�u4�� ' L z,' &�� ]�wCounws,ite Sheriff,n*=*m.Inc On March 12, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA, Known and numbered as, 839 North West Street, Carlisle, Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 12, 2013 By: C�� Real Estate Coordinator 0 '�' CUMBERLAND LAW JOURNAL Writ No. 2012-706 Civil WELLS FARGO BANK, N.A. vs. TRACY RAMSEY a/k/a TRACY BOONE a/k/a TRACY L. RAMSEY Atty.: Joseph P. Schalk By virtue of a Writ of Execution NO.2012-706-CIVIL,WELLS FARGO BANK, N.A. vs. TRACY RAMSEY a/k/a TRACY BOONE a/k/a TRACY L.RAMSEY owner(s)of property situ- ate in the BOROUGH OF CARLISLE, Cumberland County, Pennsylvania, being 839 NORTH WEST STREET, CARLISLE,PA 17013-1435. Parcel No. 06-19-1643-243. Improvements thereon:RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT:$143,863- .26. 63 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 12, April 19 and April 26, 2013 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. r �1 isa Marie Coyne, Edi r SWO TO AND SUBSCRIBED before me this 6 day of April, 2013 Notary N^;.P,RIAL SEAL OESORAH A COLLINS Notary Pubic CARLISLE BOROUGH,CLIMEERLANO COUNTY;; My Commission Expires Apr 28,201Y The Patriot-News Co. + - 2020 Technology Pkwy 14c atr1otAvXtws Suite,300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss 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 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: r 04/16/13 2011'-706 ChrR . 04123/13 WELLS FMM BANK,,NA 04130113 - vs. - TRACY RAM89Y AXIA'TRACY BOONE,A/K/A TRACY L RAMSEY ti . . . . . . . . . . . . . . AKy:Joseph R Sehalk By viriuue of a Writ of Execution No, Sworn to and subscribed before me this 13 day of May, 2013 A.D. 2012-7064CWM, WELLS FARGO BANK,N.A. VS.TRACYRAMSEY N1 00 'd J'V A�ATRp;CY BOO�, atary Public A/K/A TRACY L.RAMSEY owners) .of. property situate in the BOROUGH OF CARLISLE, Cumberland CouniciPa qYl a being {MuniEipality} COMMONWEALTH OF PENNSYLVANIA 839NORJH WEST STREET CARLISLE, Notarial Seal PA 17013-1435 Holly Lynn Warfel,Notary Public Parcel No.06-19-1643-243.t Washington Twp.,Dauphin county (Acreage or street address) My Commission Expires Dec.12,2016 Improvema* thereon: RESIDENTIAL, MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES DWELLING JUDGMENT AMOUNT.$143,$63.26 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Wells Fargo Bank,N.A. is the grantee the same having been sold to said grantee on the 4th day of September A.D., 2013, under and by virtue of a writ Execution issued on the 1 st day of February, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 706, at the suit of Wells Fargo Bank,N.A. against Tracy Ramsey A/K/A Tracy Boone A/K/A Tracy L. Ramsey is duly recorded as Instrument Number 201337495. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this .22 -X� day of y�AV-�• ��l , A.D. a ()J3 t1' xxj�- L- Recorder of Deeds 'ecorder of Dee s,Cumberland County,Carlisle,PA 11 Commission Expires the First Monday of Jan.2014