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HomeMy WebLinkAbout12-5214il. P.t3°0F1 I: . ROTHONOTA'R wNl2 AUG 21 Ali 10: 43 NIMERLAND COUNTY E*NNSYLVANIA McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Huntington National Bank 2361 Morse Road NC 1 W42 Columbus, Ohio 43229 V. Christopher A. Ramsey 85 Old Sawmill Drive Newburg, Pennsylvania 17240 and Elaine G. Ramsey 85 Sawmill Road Newburg, Pennsylvania 17240 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number , a 50) 7 &1< COMPLAINT IN MORTGAGE FORECLOSURE © a QMA'sIDS-7S?d File # 60929 Page I 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 ifyou fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 File # 60929 Page 2 COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is The Huntington National Bank, duly organized and doing business at the above- captioned address. 2. The Defendant is Christopher A. Ramsey, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 85 Old Sawmill Drive, Newburg, Pennsylvania 17240. 3. The Defendant is Elaine G. Ramsey, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 85 Sawmill Road, Newburg, Pennsylvania 17240. 4. On November 3, 2008, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for The Huntington National Bank which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Instrument No. 200836317, such Mortgage being incorporated herein by reference by virtue of Rule 1019(g) Pa. R. C. P. 5. The aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems, Inc., as nominee for The Huntington National Bank to The Huntington National Bank, by assignment which will be duly recorded in the office of the recorder for Cumberland County. 6. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 85 Old Sawmill Drive, Newburg, Pennsylvania 17240. 7. The mortgage is in default because monthly payments of principal and interest upon said mortgage due July 1, 2011 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. File # 60929 Page 3 8. The following amounts are due on the mortgage: Principal Balance $ 121,957.92 Interest through November 21, 2011 $ 3,949.78 (Plus $22.91 per diem thereafter) Late Charges $ 247.14 Attorney's Fee $ 1,450.00 Escrow Advance $ 680.87 Other fees $ 45.00 GRAND TOTAL $ 128,330.71 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 9. Notice of Intention to Foreclose under Act 6 of 1974 (41 P.S. §403) was sent to Defendant by certified mail, return receipt requested as required by that Act. Notice under the Homeowner's Emergency Mortgage Assistance Act (Act 91) was not provided as the provisions of such Act were not applicable at that time and no notice under such Act was required. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $128,330.71, together with interest at the rate of $$22.91 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY,P.C. BY: VA ? [RRENCE J. McCABE, ESQUIRE [ MARC S. WEISBERG, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE [ ] MARGARET GAIRO, ESQUIRE [ ] ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ] MARISA J. COHEN, ESQUIRE [ ] KEVIN T. MCQUAIL, ESQUIRE [ ] CHRISTINE L. GRAHAM, ESQUIRE [ ] BRIAN T. LAMANNA, ESQUIRE Attorneys for Plaintiff File # 60929 Page 4 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiff s representative, who is out of jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. MCCABE, WEISBERG AND CONWAY,P.C. f j BY: [ ] T WNCE J. McCABE, ESQUIRE [ -J- RC S. WEISBERG, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE [ ] MARGARET GAIRO, ESQUIRE [ ] ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ] MARISA J. COHEN, ESQUIRE [ ] KEVIN T. MCQUAIL, ESQUIRE [ ] CHRISTINE L. GRAHAM, ESQUIRE [ ] BRIAN T. LAMANNA, ESQUIRE Attorneys for Plaintiff The Huntington National Bank v. Christopher A. Ramsey and Elaine G. Ramsey File # 60929 Paee 5 LEGAL DESCRIPTION EXHIBIT A ALL that certain lot or parcel of ground situated in the Township of Hopewell, County of Cumberland, and Commonwealth of Pennsylvania, being Lot No. 1 in the Land Subdivision for Lucy E. Jestes, as recorded in the Recorder's Office of Cumberland County, Pennsylvania in Plan Book Volume 48, page 18, and being more fully bounded and described therein. BEING designated as Map No. 11-07-0495-016A. The 2007 Colony A3122 to be erected or already erected on said parcel, it shall be the intention of all the parties, that 2007 Colony A3122 shall be a permanent part of the realty. The Huntington National Bank Plaintiff VS. Christopher A. Ramsey and Elaine G. Ramsey Defendants IN THE COURT OF COMMON PLEAS?QF CUMBERLAND COUNTY, PENNSYLV?iNg _i ro co v rn cy `ern r- N 7u CD Sal Y Civil C D NOTICE OF RESIDENTIAL MORTGAGE FORECLO-9 UI1E" ' DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Kespectfully sub i ed. Date [ ignature of Counsel fa Plaintiff] FORM I 60929 Page I FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROW ER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email: # of people on household: Mailing Address (if different): City: Phone Numbers: Home: Cell: Email: # of people on household: First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: State: Zip: _ Yes ? No ? Listing date: Price $ Realtor Phone: Yes?No? State: Zip: Home: Office: Cell: Other: How long? State: Zip: Office: Other: How long? Date You Closed Your Loan: Total Mortgage Payment Amount $ Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: Is the loan in Bankruptcy? Yes ? No ? If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $i Other: $ $ Automobilg# 1: Model: Amount owed: Value: Automobiles#2: Model: Amount owed. Value: Other transnortation (automobiles. boats. motorcvcles): Year: Amount owed: Year: Year: Model Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly EXpensess (Please only include expenses you are currently paying) EXPENSE' AMOUNT EXPENSE AMOUNT Mortgage Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insur ce Med. (not covered) Auto fuel/r pairs Other prop. payment Install. Loan Payment Cable TV Child Supp rt/Alim. Spending Money Da /Child are/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes O No 0 If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): _ Fax: 2 Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? `!es ? No E! If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes?No? If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: 1/We, Phone: Phone: authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. 1/We understand that I/we am/are under no obiligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements f Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) f Listing agreement (if property is currently on the market) 3 ELSE IF County name MC = "Lackawanna"> The Huntington National Bank Plaintiff V. Christopher A. Ramsey and Elaine G. Ramsey Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM PURSUANT TO LACKA. CO. R.C.P. 205.2(b) and 1143(a) You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have an attorney, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact a housing counselor at either the Neighborhood Housing Services of Lackawanna County (570) 558-2490 or the United Neighborhood Centers of Northeastern' Pennsylvania (570) 343-8835 to schedule an appointment. Second, once you have contacted one of the housing counselors, you must promptly meet with that housing counselor within twenty (20) days of your telephone contact with them. During that meeting, you must provide the housing counselor with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you take these steps, the housing counselor will help you prepare and file a Request for Conciliation Conference with the Court. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, it is not necessary for you to contact one of the housing counseling agencies. However, you and your attorney must complete a financial worksheet in the format attached hereto so that you will be able to submit a loan resolution proposal to your lender. If you and your lawyer complete a financial worksheet within forty (40) days of your receipt of this Notice, your lawyer will be able to file a Request for Conciliation Conference on your behalf so that a conciliation conference can be scheduled. At that time, you and your lawyer will meet with a representative of your lender in an effort to work out reasonable arrangements with your lender. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date Counsel for Plaintiff) Signature of (Form 8 -Notice of Residential Mortgage Foreclosure Diversion Program Pursuant to Lacka. Co. R.C.P. 205.2(b) and 1143(a). 60929 Page 1 McCA13E, WI~:ISI3ERG AND CONWAY, N. C. 13Y: "I'ERRENCE; J. McCA13F., ESQUIRE - ID # 16196 MAI2C S. WEISI3ERG, ESQUIRI~. - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID #34687 MARGARET CAIRO, ESQUIRE', - ID # 34=119 ANUIZFW L. MARKOWITZ, ESQUIRE - lD # 28009 11EID1 R. SPIVAK, ESQUIRE - ID #7x770 MARISA .I. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - [D # 307169 CIiRISTINE L. GRAHAM, ESQUIRE - ID # 309480 liR(AN T. I~aMANNA, F,SQUIRP: - ID # 310321 123 South Broad Street. Suite 2080 Philadelphia, Pcnnsvh~ania 19109 (21 ~) ,90-1 U 111 The I luntin~_t~m Natiimal kiank Plaintiff ~. Chri~tupher ~ti. Ramsey and Elaine G. Ramey Attorneys f~~r ~'IaintifL CUMf31~:RLM~D COON'"l~Y COUR~1~ OI' COMMON' I'I.I~_1~ Number 12->214 Defendants ASSESSMENT OF' DAMAGF,S AND EN"TRY OF JUDGMI?~'l~ I~~) ~I~! I I. PKO~I~f(ONOI~~~RY: I~indl~ enter judgment by default in favor of Plaintiff and a~,ainst Defendants in the ,~:~ ~ ~ ~ .~~~~.~ti ~ncd rnattcr for failure to answer Complaint as required by Pennsylvania Rulos of Civil Procedure and a~~~_~, • ,~_~cs as f~~llo~s: Principal Interest lrom I I/22/1 1 to 10/1 1/12 $ 128, X30.71 l ~~tal `~ 135,776.46 ., _ ~~/ Joseph F.1 il;:~, Esquire Marg:u•et Cairo, Esquire 'I-errence J. ~'IcCabe, Esquire Christine 1,. Graham, Esyuirc Attorney for Plaintiff AND NOW, this ~ ~ day oP_~ ~~ , 2012, Judgment is entered in fa~~~~::~~ ~! ~1i1',. I he Iluntin~~ton National Bank, and against Defendants, Christopher A. fZarnsey and Elaine G. Itn~•~~~~ ~ ; ~~,.i ~L;ma~~cs ~u-c a~scss~~d in fhe amount of $ 135,776.46, plus interest and cost I3Y "I~I IE O"I~f I TA ~~~.s~~~ a"~ ~~~iso ~ r~~~ ~~ ~~~~~~ McCAl31:, W'I?ISl3ERG ANU CONWAY, Y.C. 13Y: "TERRENCE J. McCABN, ESQUIRE - ID # 16=196 MARC S. WEISBERG, ESQUIRI; - IU # 17616 EDWARD D. CONWAY, ESQUIRE - IU # 34687 MARGARET' GAIRO, ESQUIRE - 1D # 34"19 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 IF.IDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHF.N, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - IU # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE. - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (21 ~l 790-101 U The l luntin~_ton National Bank Plaintiff v. Christopher ~. Ramsey and Elaine G. Ramsey Defendants Atiorncvs fry; 1'I,ii~~'iCf COUIZ~I~ OF COMMON P1.1:;A`~~ CUM13f:RLAND COl1N~l~l' Number I?-214 AFFIDAVI"1' OF LAST-KNOWN MAILING AUDRF,SS OF DE1~1~;A~I::1`~ ! °~ COM~~10NWEAL"I~E{ OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. I'he undersigned, attorney for the Plaintiff in the within maucr, being duly sworn ar~,~~ -,,_ ~~~ lr~~~, hc;-cby depose and say that the last-known mailing addresses of the Defendants are: Christ~~phcr :~. Ramsc~ I:lainc G. Ramse~~ i;~ Old Sawmill Dri~~c S~ Sawmill Road Nc~~~hurg, Penns~~lvania 17?~~0 Newburg. Pennsylvania 17:?;' SWORN AND SUBSGI~.U3ED [31:10 , ME T IISf~ ~<_/ DAY ~ _, ,/ ' ,~ ~ ~ -- ~ - -~~ .lt~ 1 . ~O ;~[ Y PliL3L1C ., .. ~ _ ~,; Barba ~ , r ;a}~y ~'~sc, ~~ ;ity of Pt _ i~ Philadelphia Co~~rty Joseph Ri~,a, Esquire M:u-ga I ( -iro, Esquire 'Terrence ,1 McCahe, Esquire Christine L. Graham, haquire Attorney for Plaintiff PP1~1cC,ABE, WEISBERC AND CON WAY, P.C. BY: "TF.I2RENCE J. McCABE, ESQUIRE - IU # 1649E MARC S. WEISBERC, F,SQUIRF, - IU # 17616 Ii:UW;~RD U. CONWAY, ESQUIRE. - ID # 3468 MARCARF~'1' CAIRO, ESQUIRE - (U # 3441) 123 South Broad Strecl, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 ~I~hc E iuntington National Bank ~~ Plaintiff ~. Christo~~her %~. 1Zamscy and Elaine G. Ramsey Attorneys fur f'I,~in?il'f CUMBERLAND COUN~f`r LOUR"1~ 01~ COMMON PI.1~;+. `• Number 12-~21d Defendants AFF[llAVIT AS TO MILITARY SERVICE, I~hcrc~a Benoit. being of lawful age and being first duly sworn on oath, states and dcp~.~;r- ~:, ;~~,~~ s: I . I am a Legal Assistant at V1cCabe, Weisberg & Conway P.C. ~. On 1 lthdayofOctober+2.012. I personallvcimductedanonlincsearcht~~~,~~.~ u!li_ i~epartment of Defense ~°lanpo~~~er Data Center at https:/hvww.dmdc.osd.rnil/scra/owa/home. ~~': ~_'~ icated that the defendants, Christopher ,l. Ramsey and Elaine G. Ramsey, was not in the military scrrice , ~ ~ ~_° ~ " !eel States as of the date I conducted the search. A true and accurate copy of the printout of the online ,.~,°.~, '~~ _~s,i:lls from the Dcpartrnent of Defense Manpower Data Center is attached hereto. ~fo me kno~~~ledge, defendants. Christopher n. Ramsey and l~aaine G. It ;,,,~~ ~, fait an infant or an meom;~etcnt. 1 affirm, under the penalties for perjury, that the foregoing representations ^rr /r~ . ti!~()RN ~1N1) SlJl3SCRII3f:I> 13y. ~~-_~-]. ~~~, L- '~ --'~ ~ ~ '. r ~ ~` HI~:PUKI~ ~~II~. 11115 DnY "I~heresa f3cnoit ~ ~I~ .3012 '`U',.-11:1' I'l IiLI(' McC,1Bl~:, Wl?IS131':KG AND CONWAY, P.C. 13Y: TERRENCE J. McCABF., ESQUIRE - Ill # 16496 MARC S. WEISBERG, F,SQUIRI; - ID # 17616 F:DV1'ARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 FIEIDI R. SPIVAK, ESQUIRE - ID #74770 ~7ARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, F,SQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 13RIAV' "T. LaMANNA, ESQUIRE - 1D # 310321 123 South Broad Strcct, Suite 2080 I'hiladclPhia, Pennsylvania 19109 (Zl~) 7')0-1010 1 he I lur~tinaton National Bank Plaintiff v. Christ~~pher ,~. Ramsey and Elaine G. Ramsey Defendants Attorneys fr~r I~lai?itil'f CUML3ERLAND COUN~II' COUft'I~ OF COMMON` PI.I:;A'~ Number 12-214 CF,RTIFICA"PION l•he undersigned hereby certifies that he is the attorney for Plaintiff, being duly s~a~u , _ .~~n~~ :o la~~~ deposes and says that he deposited in the Un?ted States Mail a letter notilying the Defcnd~u~t> ~'~~.r ~~tm~~nt w~wld be entered a~~ainst them ~~ithin ten (101 days from the date of said letter in accordance ~~ ith Itu!~~ ,_ Prnn;~ Iv~ania Kules of Civil Yroeedure. A copy of said letter is attached ha-eu> and marl:cd .:~- ~ ~ `.~ SwOlZ1`J nND SU[3S ' E3 [?D 13t:1~(_>,{~~MI I~ 11S ~ DAY O I' ~~ ~ "'~~-- _ • ~ 0 y ~ / NOI nRY PlII3LIC ~~, Jo ,ph {~. 2iga, Esquire fllargar Cairo, Esquire Terrence J. iVlcCabe, Esquire Christine L. Graham, Esquire Attorney for Plaintiff G'rea ~;i .. .. . MY CU's ~s . _ VFRIFICA'I'IOV' I~he undersigned attorney hereby certifies that she is the ,Attorney for the Plaintiff ir. •I .~ .~~.!ti i~~~ action. and that she is authorized to make this verification and that the forcgoing~ facts based on the inf~ui,~.~'.~~~ '-~~m the Plaintiffs rcE~rescntative, who is out ofjurisdiction and not available to sign this verification ~.' ~- ,•_ .ire true and correct to the best of her kno~~~ledge, information and belief and further states that false staten~,~r.~ , ~.~~ ~ in arc made subjeet to the p~~naltics of 1 S Pn.C.S. ~~190~3 relating to unsworn falsification to authoritic;. Joseph Riga, Esquire Margar t Gairo, Esquire "I~crrenec J. ~1cCabe, Esquire Chris-ine 1,. Graham, Esquire Aftornc~~ for Plaintiff O~1+iCl+: OI+' "t`III', PRO't`(IONO"1'ARY CO U1Z'I' O1~' CO1~'I vl ON f'LL;AS Curnberlancl Coun~fy Courthouse, Carlisle, 1'enns~'lvani.- 1 "'! i Curt I,n-a~; Prothonotary Se~~te-i~ber 14, 201 ~(~Iv: Chrishpher .~~. Ramsey ~~ C)I1 SuYVmill Drive N~~Y-vlyur~ Pennsylvania 17240 I~!~i~~ I~,ntin,t!cu~ NcI(i~vnal Bank C>_unherland County ~.; , Court oi_'Com~~~on Pleas C"hrist~~pl~icr ;~1. 1>`an3s~y l;laine C~~. Ramsey Number 12-214 Civil NOTICE PURSUANT' "I'O RULE 237.E NO'1'tC7~; Oh' IN'1'F.N'i'ION TO >aILE PRAECII'h; TO i~.N'hT:i2 ,Ii?I)(,d~il~"'~i '~`~ Ii~~IPOIl"I'AN'1' NOTICE l~n .;~ 1P. ~~ rAl'Lf t, c%,usl; You IIAV1~ r-A1L1a~ ~ro e,vTl~1z n 4I ..~,., ~!'PIiAI: ~:L i'Gfi40Ni~Ll.l' OR 131' A'f'CORNBY AND FILL IN 41, ';6(! :=.lil 111 ~, t Oi;R'i vO111t )I I~INSIS (iR Ok4J8C"PIONS TO "IIiL _I ~Irtti ii 1 ~`~~ fl ,.G MINA 1'UU. UaI I,:S,9 YOJ ACT \A~I~C1iIN T6N ~~~) I I~a _.. i L :?r I ~'. I ~ '~i(;TIC:.I. A JUDIrVtIiN f <v1AY 13G GN'iF,RHD ,~i ~,r-lS. ~.t ..'I !l ~.'UT.,III-~AJI~!<1;AP~h YUU MAY LOSL YOUR PROPI=.RTV' )R ~ "Il li: ~ AI'Cii,: I ~~.1 1211 r. ;l ti. ~'i~U S :C:,D T ~._! ll ITS I X17::;"I;J YOUR I~A`N'~'I:RA"f ONCE. 1F YOU DC, .`-0"I ! i.'. ~.'![ ,1 I.l. ~ 1 I:R, t10'.O (iR TI 1_EP110Nc TI-IIi OPPIi'C Slil POIYII I I31-:LUti'. ,l ll~ (Yrl ii elf C1N I.,OVIDI~YOU Wf~('ll INFORMATION ABOiiT IPYOtC ,'J;-~O";:.:I~(iPI>'f01!IRP~V_AN'YER,T[IIS(\FFICI;MAY[3BA131.L 'I~O I'ROA I[ ~I~ 1'i )U W I'f I-I It`!POIi Vi AI.ON A130UT AGBNCII;S TH.1T MAY OFPISR I I t,.'11, ~'.7".'li'1-:S 1 ) U.',It;l131.1. I HRSONS A"1' A RF,DUCI:D I~li3 OR NO I~EI?. Cun;l~cii~ir~ti C`uunn~ F~nr iAssociNli~m 3-'. Sou1~1 I'~adCorl ~t:cct C,ai':iIc. I'cnusYlr.. ~,r,: 1iUl (hl)il) ~)`+U-~~ I ~)8 I) I? FA U L"1' :VOTIFICAC'IO'~ : ~~!'OR"I'AN'1'1~; UJTG6 Sli 1?NC:U1:'~171~A li>; L. I.tIsStiN"!'ADO U'v,A C~;A41"~. I'I?RhUNA~. ~tI:N'll? f) I'(lR 4ii~' I.~CItITO CON 1-:5'I'I I~1.131"~~:~- :. t!,CI,Ati90S PORAdl 1,l k~i ' A.;CION DI~.131DA U;,P-f fl(~)!;I 1... "J OIII'iCAC K)1`J, i3t 1 R:'.il. < -- COMPARE CER US~I'I`) IC?v' ~: til;iv~ rr.NCin t:rv~ su ~ crI I r.:;, ,: _ _ Dr:RECI-105 IMPORT A'~ ;T1S US'11U LG ~'.'13ft i .... INr`n~:nlA I vrvlrti._:,: SI us~,~: _,LdI`ONEA LA OPICIi".~ 1-.:•:i'1:~~ I'KOPCRCIONAR C~-)N IhF~~': '.:. A I;f ~GADO. S]USTGDNOPLF:DI,I'R(;'i~i: :. IaTA OFICINA YUFDG Si~a; INPi)KM~('.16NACf:L'ni~I~:~, "~. sl:xvu;;~~~ t,t~cnl.rs ,, P~:~~~ ItIsDUC[DO NI NSNGUPd I10 `O}t'-,. ~~~~unherland Coway 13a::~: ~~~; :S? ~;outh 13edCord J:rrci C;~rlisli.I'cnns~~vnliia ~_~ ---~-'"-~"-- (t;UOj 99D-910}; 13Y: , Att--rneys for Plaintiff '1'I?RRL;NCT J. McCARI?, 1?SQUiRE MARC S. WECSI~I!,RG, 1?~QUIRE EDWARD D. CONWAI', I';SQUIRP; MARCARI;'1' GAIRO, i~;SQ[TiRi? ANDRi~;W t,. MAItKO~~~~1'C'l,, ESQU(Rr CHRIST[Ni': L. CRAtIA!tit, ESQUIRE; ~t rrl..a [~o1t ro rl.vitr. ,c,zrr,~, vn sr:n i. ~_il~it R,1L'ICAt)O POR .. - ~ slsraONFS A 1.03 A NiJ ~I'>AL1R LA . ~I.~:IiA I:i FiS~I~A JGCI'.ti:DAD DIr; ~K fill[N1:~UGIIiCS ,v ~;u nlux~nul~ I ,nui~nDO, •; n n o ' f'_. LUh' ~\RGGADQ bii 7r~:~('IONAi2L0 CON ~: u>`~ llorrounau> ol~hlcE or~ ~~Ilr P~zo~r~~~.~~~Io~rntz~~ cot~iz~r or cc~~I~I~>~ i~L,~-fps Cumberland County Courthouse, Carlisle, Penns~~ivania I "I~ 1 .~ Curt Long Prothonotar-~ s~~ten~eer ~ ~~_ ~~~I ~ ~I~~1: I~lain~ (i. I~amsev S~ sawmill Koad Ne~.~~hurb, Pcnnsvlvania 17240 "f~hc i-Iurltili,~t~In National [Sank Cumberland County vs. Court oi~ Common Pleas Clu~istopher ~~. Ramsev Elaine ~~. Ramse~~ Nuulber l2-~<?14 Civil NOTICE PURSUAN~1' "1,0 RU1,F, 237.5 NC-"I'[Cl~; OF iNT[?NTION TO FILL, PRAECIPI~;'I'O LN'CI{;R JUUCI~II~:'el~ ;31" 1)I~:l~~~U1.'1' INIPOR'I'ANT NOTICE I~UIi .v1:11 IN I~li:•Al1Cf I3L(~AJ.iF YOU FIAVF fAILGD "f0 EN'fP,R A WRI~1°fl',fv Al'i'L:~ILvtvl I:: ;'!::itSQ;IAI'.,Y OR I3Y ATTORNHY AND FILP; IN \bHl"I'I K(. \~'i (il l'lla ~~~hUItT YOlil: DI:PIiNSGS OR 061EC'1'IGNS 'I'O "fIIP: ~.,AIn-IS sr r roI.T1: nc:vINS r Ycxi. tJNllss you nc"r wrrrt~N T:-N (10) DAYS F120!~9 "fl II-. D.AT.OF"1~I11S NO"fICB, A;UDG<v1GN'I' MAY P:E L-:PJ"fF.RGD ,aGN\S'I YO.~'J~''I'IIOIi"I~AFIEARING~IND YOU MAYI,OSH YOUP.PROPBR~IY Oil OT!-IF.R I<`4PORT;~N"1- RIGI frS. YOU SI-16ULJ l~.'lhii ~PI IIS PAPER TO YOUR LAWYER A I' OtvCE. IP YOU DO NOT [i;',V I'. /~ I.A`,4'sl{R, GCi ~I~(7 OR TGLh:PF10NE l IIE OPP1Cf SI`I FOR~II-I 13 cLO V,'. .~ fl ; t`[=Flt r i'A'J PR(1 /iDE }'(1U Wffl1 INPOR MA"LION ADOU~I' IiIRING A I iA~1'YGR. 1P YOU C APBVU1~ ~~ PI CiKD TO tIIItCA LAWY'IiR, l"Ills CPIICI~. VIFlY 13LAISLE I) I <; iV l'JI: ~ ~)t W f ~i l INPORMATIOPJ ABOU~I'AGENCIGS'frIAT tviA'r OPfi~iL LC 11. SPI< ~ ~.~ ~I~ i `.~_GIL'l.l? P-:R~ONS A?~ A RFUUC6D I Iili OR NO P6E. Cinuhcrlunu ('u.m,v ha. ,~~SOCIfl~IU^ 3~ Sut;th 13 :I!~ord Slr~_et t~arlisl~:, I'iauis.I~n[, r I~ifil SOD) '~'>fL9I nS NO'TIFIC.A('I(-~' I'~tl'"{)12'1'~N'I'I+; I1S'IISD SC I;NCl.1=.N fI,A i;A I ~~! `. i'..I U.~ PUh NO FIA(3IiR PRI'.SIiN'fADO UNA lS)N.I','~.P.i: ~i'i:IL\, 'I ,4 S73A Pq:RSONALEv11,iN"CE O I OK A3C~;i` , ~ .. ~, ,-~t IL,4DICADO POR hs~rrro coN rsrl~"l~a:lll;rvni, c ~ gall?cloNrS A Los REl'LAMOS PORMULADOS I~.Y Ci:'~ - ,. ?:O "IOMAK LA ACCION DGBIDA llfiA'TKO L)i'. ;J ' '. ~ ... I~r;CHA D13 C;S'fA N~_;~:IPfCACION, EL 1~R113t~~':A: ~'I:('ESIU,4ll DC C(NdI'.AKIICER USTGli I~.N C~'ft~.!' _., _SiI;NA, UIC"fAIZ SLYTE:NCIA FIJ SU CONTRA S C ~ ~' .'~ 3S l; O'fROS U'I,ECf-'.OS IMPORI'AJ'IIfS. U.~~rrn ..f 7>I s:: ~:r;'. ~~_: ~ ~, su nl;o~nf,o 111 vIrD:A~fAAtl,N fif. SI 't: '!, - ~f!V iO, JA A it l~l LLI-OVE^. LA Oi'I C'liv~ I ~',!. ,~ - IYf, L(1 !"il~:Ult Plb:?I'ORCIONiAIt COP. INr~)I<^.'-'. - .A11'1 J{-A!' A ~~A' AI3UG:ADO. ~ ~ CBD tv0.U1:DI_ I t'>i :;.., ,~ ~ Its n~luCi:U)1), rs rn oru~INn Pur:uf self <~ ~ ~ ,.~~ ,~ . ~o~~~.~P.LO coN iNPOR61AGibNACBR<~ U::,.:5 ~.~. ~ :;. ~Z,tiOPRIiCI-:R1.0$ SL2Vh~70S L}.GALBS ~ "I;ii:S~r`,:A. !:J i'UNUP. A1tIU Itl{UI ~~_'IDO NI <vlNi iUN i IONOIt:A'.2 Cumberland Countv R~ir A:;rx~~,: 3?_ South f3edford Strcat Carlisle. Pennsylv~rnira 1701 ± ,e-~---",.-"__." (8001 990-9 1 08 ,^' ~.- ~r'a. ~Y: ~ ~ Attorneys for Plaintiff 1'EI212ENCE J. McCA131?, 1?SQUIRI? MAi2C S. ~VI%ISI3ERG, I;SQI11R1; EDWARD D. CONWAY, 1?SQUIRI?. MARGART'I' GAlllO, I?SQUIRI; ANUREW L,. MARKOWI7l,, I;SQUCRI CI~RIS"TINT: L. (;RAIIA~bi, ESQL1112I: s: Department of Defense Manpower Data Center ~~ ~~~ ~~~" ~ar~`5 s,a~n z s "`- ~~LS1tiLJtICII thS ~'Iti~LCi'[77l'[77~t~C:~ ~~[V1~ 1'~C~tl'i f~l'~ Last Name: RAMSEY First Name: ELAINE Middle Name: Active Duty Status As Of: Oct-11-2012 On Active Duty On Active Duty Status Uate Active Duty Start Date Active Duty End Date Status ~ r,9ce ;omponent VA NA No ,, This response reFlecls tha individuals' active duty status based on the Active Duty StaWS Date Left Act ve Duty Within 3B7 Days of Artive Duty Status Date Active Uwy Start mate Active Duty End Date Status ~' , , E.:_ xnponent VA NA No i his r ~sponse reFlecls where the individual left active duty status within 367 days pmcoding the Active Duty S•a ~..: , The Member or HislHer Unit 1Vas Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order NoC~flcalioa Start Date Order Notification End Date Status ~ ~I , r. _ r. ponont ~~ NA No . , this response reflects whether the individual or his/her unit has received early notiflcation to repute for a;"'wr :~..'. Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that yon, :: ~ ~ n ~c: a~tove is the status of :he individual on the acive duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air ~ ;: ~.,>n~. f'uolic Health, and Cot3st Guard i- This status Includes information on a Servicemember or his/her unit receiving notification of future ort;ur_ :: ~. ~ !'•cve Duty. ,~ ,cam,-.~~ Mary M. Snave'~y-Dixon. Director Department of Defense -Manpower Data Center 4800 Mark Ceraer Drive. Suite 04E25 Arlington. VA 2?35~J The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains ~~~; ~ ~~~e~tt and Eligibility Reporting System (DF_ERS) database which is the official sow~ce of data on eligibility for military medical care and oti~e~ ~~ The DoD strongly suppors the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as a~ne-u.:c Inr-terly known as the Soldiers' ane Sailors Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any ~,frr ~ ~ ~~a cuGny that the individual is currently on active duty" responses, and has experienced only a small error rate- In the even? the indiviau~ ~~ ° ~r~ ;uor e. or any family member, friend. or representative asserts in any manner that the individual was on active duty for the active duty status c.3~i r. ~cn~ise entitled to the protections of t+~e SCRl~. you are strongly encouraged to obtain further verlflcation of the person's status by contacting t~•rr :,,~ _. ~er.~lee via the "defensehnk. ml" URL_ itttp7/www.defenselink.miUfaglpis/PC09SLDRhtml. If you have evidence the person was on ar .~~_ . ~u: a.aive duty status date and you f i ! t~ obtiiu this additional Service verlflcation, punitive provisions of the SCRA may be Invoked agates y:~, : SC l1op. § 521(c). This response reflects the following inforrnatlon: (1) The individual's Active Duty status on the Active Duty Status Da-e ~, ~ ~ ~~~r. icdroidual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the Individual or his/her unit receives e~~~ ; ~ ~ :: report for active duty on the Actve Duty Status Date. More information on "Active Duty Status" Active duty status as ~eported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only si~~^~ ~ ~ ~ ~~ er~cuty periods less than 30 consecutive nays in length were available. In the casE: of a member of the National Guard, this includes serv;a; _r ,., ~c ;: ,rive scxvice aushorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a nat~~o-tai e-~~~- __ ;v :;ec~.tre:d by the President and supported oy Federal funds. All Active Guard Reserve (AGR) members must be assigned against an autro ,:_ ~ .c; ~,r<t'~ion position in the unit they support This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve !:~ z- _ .Coast Guard Reserve Program Admin~strak:r IRPAs). Active Duty status also applies to a Uniformed Service member who is an active duty <<~,~•~~ ~ , r,'fr;e~ of the U.S. Public Health Sew'~ce or (tie National Oceanic and Atmospheric Administration (NOAH Cornrnissioned Corps I. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes ~~ Zia .V^o would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for ,3 ~ ~ ~., 3erwces periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1 ). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons secs ~~~~ ~ ~ ~~ !~~,is website certification snou~~d check to make sure the orders on which SCRA protections are based have not been amended to e.x:n~~ ~ ~ ; ~~_ dates of service. Furthermore. sr>me protections of the SCRA may extend to pe~sons who have received orders to report for active duty o' ;~ ~, ..'e:1. out who have not actually begun active duty or actually reported for induction. Tne Last Date on Active Duty entry is important because a ~.,~ _ ~ cep ;.ons of the SCRA extend beyond the la~~: r:etes of active duty- 'those who cuu'r. rely n~, Grlis certificate are urged to seek quaGfled legal counsel to ensure that all rights guaranteed 'o Sr ~ ~ ~ ~ ~_ ~i,,der the SCRA are protected WARNING: This o~rtificete was proviced based on a last name, SSN/date of birth, and active duty status date provicer, ~, ~ _ ?roviding erroneous infrxmaton will cause an erroneous certificate to be provided. Certificate ID: JMVOP2UOA9 Department of Defense Manpower Data (;enter -'~ - tiLtiLU~ K~I)C>~l - ,~. ~,, ~:-_~'~- ,~` Purauzint iu Sc~rvic.t~tl~~~t~~h~r~ C'iw~il l~~~li+v~f'.~~rt Last Name: RAMSEY First Name: I~HRISTOPHER Middle NamE:: Active Duty Status As Of: Oct-11-2012 ~~,-~ ~-aotz to 3a se scrtA 2s On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status .~. r~r.:e ~:omponent This response reflects the individuals' active duty slaws based on the Active Duty Status Ua'e Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status ~ ,, ;e ~ ~ur~aonent NA NA _~_ No .~, This response reflects where the individual left active duly status within 367 days preceding the Active Duty Sa:_; :.. The Member or HislHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date __ Order Notifcaflon Start Date Order Notification Fnd Date Status ~. a C.o=nponenl r,A NA No .~, This response roflects whether the individual or his/her unit has received early notlf~cation to rrporl for activo r:.. r; Upon searching the data banks of the Department of Defense IVlanpower Data Center. based on the information ?hat yo.l _:~ t~ ~l;,ovc is the status of the individual on th~~ active duty status date as to all branches of the Uniformed Services (Amy, Navy, Marine Corps, A~~ ~ : ~, ; ,~;>lic f ieafth, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orde~~ ., ~~ ^ ,~c Duty. ~~ Mary M_ Snavely-Dixon, Director Department of Defense PAanpower Data Center 4800 Mar'K Cen'e~ Drive Suito 04E25 Arlington. VA 27350 OFFICE OF THE PKO"I'tIONOTARY COURT OF COMMON PLI?AS Cumberland Count~~ Courthouse Carlisle, Ncnnsy~lyania 17013 Prothonotary ~fo: Christopher n. Ramsey 8~ Old Sawmill Drive Nc~ti~burg, Pennsylvania 17240 ~i~he l luntin~~ton National [3ank Plaintiff v. Christopher ,~. R,unsey and 1=,lainc G. Ramsey Defendants COUR"f OF COMMON PIJ~:1~~ CUMf3FRLAND COUN~I~I" No. 1 2-S? 14 NOTICh: Pursuant to Rule 236, you are hereby notified that a JUUGMI:N"I' has been entered ~,,~ pro~~~din~~ as indic;ned brlo~~~. X Judgment by Default _ Money Judgment Judgment in Replevin Prothonotary ~ohq~~a- __ Judgment for Possession If~~ou h,i~~~ any ~~uc;tions conca•ning this Judgment, please call McCabe, Weisber~> and C~~n~in- -- - -- P.C. at 1 ? 1 SI 790-1010. OFFICI? OF TIIF, PIZO"('lIONO"I'AR1' COURT OF COM MON PLI?AS Cumberland Count~~ Courthouse Carlisle, Pennsylvania 17013 Prothonotar~~ fo: I~;laine G. Ramsey 8S Sawmill Road Ncwbur~~. Pcnns~'Ivania 17240 l~hc I lunlin<~ton National E3ank Plaintiff ~. Chris~opi~er .1. Ramsey and Elaine G. Ramsey Defendants COURT OP COMMO~~ PI.I~.A`~• CUMf31~:ItLf1ND COON"I~l' No. 12-5214 NOTICb: Pursuant to Rule 236, you are hereby notified that a JUDGMI?NT has been entcrc~l i~ ~ ~~ ~~ ~~ ;~rocecding as indicated below. _X_ Judgment by Default __ y'tonev Judgment __ Judgment in Replevin __ Judgment for Possession ,t. Prothonotary ~ +ti ,,,,,~ ,,,,r If~you have ane questions concerning this Judgment, please call McCabe. Weisber~~ and C~~n~~, ~- P.C. at (? 1 X790-1010. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALT>-i OF PENNSYLVAN[A} NO. 12-5214 Civil COt1NTY 01= CUMBERLAND) CfVILACTION LAW 7Ya THL~ SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE HUNTINGTON NATIOPVAL BANK Plaintiff (s} From CHRISTOPHER A. RAMSEY AND ELAINE C. RAMSEY (1) You are directed to levy upon the property of the deferndant (s)and to sell SEE LEGAL DESCRIPTION . (2? You are also directed to attach the property of the defendant(s) not levied upon in the possession of C~ARNISHEE(S} as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s i or otherwise disposing thereof; 1.31 If property of the defendant(s) not levied upon an subject to attachment is found in the possession of~ anyome other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: 5135,'776.46 L.L.:.50 Interest from l0/12/12 TO 3/6/13 53,258.72 AT $22.32 PER DIEM Atty's Comm: `io Due Prothy: $2.25 Atty Paid: $215.25 Other Costs: Plaintiff Paid: Date; (0/26/12 ~~fd') Rci~~UESTIItiC PARTY: Nan1e: -IOSF,PI-1 F. RIGA, ESQUIRE Address' >!'ICCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790•-1010 Supreme Court ID T~fo. 16496 "\ _ .~~~~~ l1~-_.._._ ___.. ____.. David D. uell. Prothonotary By' --- Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION The Huntington National Bank v. INTEREST: from 10/12/12 to 3!06/1'3'-~_~~ ? 3 258.72 at $22.32 C~er diem ATT`~''S COMM.: -:_ COSTS: - - -- TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract. or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Christopher :~ Ramsey and Elaine G. Ramsey PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) _ 85 Old Sawmill Drive, Newburg, Pennsylvania 17240 _.__ (More fully described as attached) ~~~ , s~ ~ ~~~ C~~ ~ ~ ~ ao 2 ~~ C(f~ ~• S PRAECIPE FOR ATTACHMENT EXECUTI0IV Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply tour copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s1~. (Indicate) Index this writ against the garnishee(s) as a lis pendens against rea_1 estate of the defendant(s) described in the attached exhibit. ~'~ DATE: ~~~t~~5~~ ` Signature: Print Name: J Firm: MC~ Address: 3 WF.,ISB~'RG AND CONWA''r' Philadelphia, PA 19109 Attorney for: Plaintiff _.. Telephone: X215) 790 1010 __ Supreme Court iD No. 16496_ Lt N ®~.~aS.~ ~ S ~~ ~_~ ~w 5 FILE NO.: 12-5214 Civil Tenn AMOUNT DUE: $1:15,776.46 50 LI~- (?~~ I~1~S83 -~~a~a~l ~ II ~ ~ ~,'V~1 ~ lx.~ LEGAL DESCRIPTION RB5678 85 Old Sawmill C~rive, Newburg, Pennsylvania 17240 ALL THAT CERTAIN lot or tract of land, together with improvements erected thereon, known and designated as Lot No. 1 on the hereinafter referred to subdivision plan, situate in Hopewell Township, Cumberland Coi.n~~ty, Pennsylvania, bounded and described as follows: BEGINNING at a concrete monument set at the northwesterly most corner of the within described lot and set in line of lands now or formerly of John J. Clippinger; thence along line of lands now or formerly of John J. Clippinger, North 61 degrees 39 minutes 20 seconds East, 277.05 feet to an existing stub in stones, the corner of the within described lot and corner of lands now or formerly of George A. Hoover; thence alon;~ line of lands nc~w or formerly of George A. Hoover, South 24 degrees 53 minutes 14 seconds East, 509.93 feet to an iron pin in line of lands now or formerly of Pennsylvania Turnpike Commission; thence along line of lands now or formerly of Pennsylvania Turnpike Commission, South 76 degrees 58 minutes l3 seconds West, 282.58 feet to an iron pin at corner of other lands now or formerly of Gary D. Jester and Beverly June Glanville, now Beverly June Hardy; thence by Lot No. 2 as shown on the aforesaid plan. North 24 degrees 53 minutes 14 seconds West, 435.15 feet to the point and place of BEGINNING. CONTAINING a total area of 3.000 acres. The above description is in accordance with subdivision plan entitled "Land Subdivision for Lucy E..lestes" recorded August 7, 198, in Cumberland County Plan Book Volume 48, Page 18, which is intended to correct, revise and supersede the plan recorded in Plan Book Volume 41, Page 87. The above described lot is SUBJF,CT TO an existing 16 foot right-of--way and 50 foot wide dedicated right-of--way along the southerly property line and extending the full width of the lot. BEING the same premises which STEWART P. CRAIG AND COLLEEN RAE CRAIG by deed dated September 7, 2007 and recorded September 10, 2007 in the office of the Recorder in and for Cumberland County in Deed Book Instrument No. 20073 1 12, granted and conveyed to Christopher A. Ramsey and Elaine G. Ramsey, hushand and wife, in fee. fAX h1AP PARCEL NUD/1BER: 1 1-07-0495-O16A McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 ANDREW L. IvIARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - [D # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215)790-1010 The Huntington National Bank Plaintiff v. Christopher A. Ramsey and Elaine G. Ramsey Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 12-5214 AFFIDAVIT PURSUANT TO RULE 3129 -- , L.; -_~_ -..-~ `_ c ~~+ The undersigned, attorney for Plaintiff in the above action., sets forth the following information concerning the real property located at: 85 Old Sawmill Drive, Newburg, Pennsylvania 17240, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. Name and address of Owners or Reputed Owners Name Christopher A. Ramsey Address 85 Old Sawmill Drive Newburg, Pennsylvania 17240 Elaine G. Ramsey 85 Old Sawmill Drive Newburg, Pennsylvania 17240 2. Name and address of Defendants in the judgment: Name Christopher A. Ramsey Address 85 Old Sawmill Drive Newburg, Pennsylvania 17240 Elaine G. Ramsey 85 Sawmill Road Newburg, Pennsylvania 17240 3. Name a.nd last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein ~. Name and address of every other person who has any record lien on the property: Name Address None <. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Address 85 Old Sawmill Drive Newburg, Pennsylvaniai 17240 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Department of Public Vdelfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard l 10 North 8`h Street Suite #204 Philadelphia, PA 19]0"1 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 28123(1 Harrisburg, PA 17128-11230 PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Attv General of the United States 8. Name and address of Attorney of record: Name None PO BOX 280948 Harrisburg PA 17128-0948 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group Williarri Green Federal Building Room. 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 31 I Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 51 1 1 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 2053(1-0001 Address 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 mad~ly~ect to t~penalties of 18 Pa.C.S. i i Section 4904 relating to unsworn falsificatig,~a to authorities. '~~~ ~ C~ _ ~O `~~ '~ f < _i i_° Joseph F. a, Esqui ; -' DAT1= Attorney for Plain LEGAL DESCRIPTION RB5678 85 Old Sawmill Drive, Newburg, Pennsylvania 17240 ALL '1-HAT CERTAIN lot or tract of land, together with improvements erected thereon, known and designated as Lot No. I on the hereinafter referred to subdivision plan, situate in Hopewell Township, Cumberland County, Pennsti lvania, bounded and described as follows: BEGINNING at a concrete monument set at the northwesterly most corner of the within described lat and set in line of lands now or formerly of John J. Clippinger; thence along line of lands now or formerly of John J. Clippinger, North 61 degrees 39 minutes 20 seconds East, 277.05 feet to an existing stub in stones, the corner of the within described lot and corner of lands now or formerly of George A. Hoover; thence along line of lands na~w or formerly of George A. Hoover, South 24 degrees 53 minutes 14 seconds East, 509.93 feet to an iron pin in line of lands now or formerly of Pennsylvania Turnpike Commission; thence along line of lands now or formerly of Pennsylvania Turnpike Commission, South 76 degrees 58 minutes 13 seconds West, 282.58 feet to an iron pin at corner of other lands now or formerly of Gary D. Jester and Beverly June Gianville, now Beverly June Hardy; thence by Lot No.:? as shown on the aforesaid plan, North 24 degrees 53 minutes 14 seconds West, 435.15 feet to the point and place of BEGINNING. CONTAINING a total area of 3.000 acres. The above description is in accordance with subdivision plan entitled "Land Subdivision for Lucy E. Jester" recorded August 7, 1985, in Cumberland County Plan Book Volume 48, Page 18, which is intended to correct. revise and supersede the plan recorded in Plan Book Volume 41, Page 87. The above described lot is SUBJECT TO an existing 16 foot right-of--way and 50 foot wide dedicated right-of--way along the southerly property line and extending the full width of the lot. BEING the same premises which STEWART P. CRAIG AND COLLEEN RAE CRAIG by deed dated September 7, 2007 and recorded September 10, 2007 in the office of the Recordeir in and for Cumberland County in Deed Book Instrument No. 20073 112, granted and conveyed to Christopher A. Ramsey and Elaine G. Ramsey, husband and wife, in fee. TAX MAP PARCEL NUMBER: 11-07-0495-016A McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIV.AK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW The Huntington National Bank v. Christopher A. Ramsey and Elaine G. Ramsey Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 12-5214 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Christopher A. Ramsey Elaine G. Ramsey 85 Old Sawmill Drive 85 Sawmill Road Newburg, Pennsylvania 17240 Newburg, Pennsylvania 17240 ,_, _. :c, z<__ -~.~ ,, ~: ~~,, Yaur house (real estate) at 85 Old Sawmill Drive, Newburg, Pennsylvania 17240 is scheduled to be sold at Sheriffs Sale on March 6, 2013 at 10:00 a.m. in the Commissioner's Hearing Re~om located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $135,776.46 obtained by The Huntington National Bank against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to The Huntington National Bank the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must: pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. ''. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you whll have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER. RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C.., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, ,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount dine is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. ,A, schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. ?. You may also have other rights and defenses, or ways of getting your real estate ba~.k, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE iVIAY BE ABLE TO PROVIDE YOl! WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER. LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania I7013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 117013 (800)990-9108 LEGAL DESCRIPTTON RB5678 85 Old Sawmill Drive, Newburg, Pennsylvania 17240 ALL THAT' CERTAIN lot or tract of land, together with improvements erected thereon, known and ~;iesignated as Lot No. 1 on the hereinafter referred to subdivision plan, situate in Hopewell Township. Cumberland Co~.mty, Pennsylvania. bounded and described as follows: BEGINNING at a concrete monument set at the northwesterly most corner of the within described lot and set in line of lands now or formerly ~of John J. Clippinger; thence along line of lands now or formerly of John J. Clippinger, North 6l degrees 39 mimRes 20 seconds East, 277.05 feet to an existing stub in stones, the corner of the within described lot and corner of lands now or formerly of George A. Hoover; thence along line of lands now or formerly of George A. Hoover, South 24 degrees 53 minutes 14 seconds East, 509.93 feet to an iron pin in line of lands now or formerly of Pennsylvania Turnpike Commission; thence along line of lands now or formerly of Pennsylvania Turnpike Commission, South 76 degrees 58 minutes 13 seconds West, 282.58 feet to an iron pin at corner of other lands now or formerly of Gary D. Jestes and Beverly June Granville, now Beverly June Hardy; thence by Lot No. 2 as shown on the aforesaid plan, North 24 degrees 53 minutes 14 seconds West, 435.15 feet to the point and place of BEGINNING. CONTAINING a total area of 3.000 acres. The above description is in accordance with subdivision plan entitled "Land Subdivision for Lucy E. aestes" recorded August 7, 1985, in Cumberland County Plan Book Volume 48, Page 18, which is intended to correct, revise and supersede the plan recorded in Plan Book Volume 4l, Page 87. The above described lot is SUBJECT TO an existing 16 foot right-of--way and 50 foot wide dedicated right-of--way along the southerly property line and extending the full width of the lot. BEING the same premises which STEWART P. CRAIG AND COLLEEN RAE CRAIG by deed dated September 7, 2007 and recorded September 10, 2007 in the office of the Recorder in and for Cumberland County in Deed Book Instrument No. 2007351 l2, granted and conveyed to Christopher A. Ramsey and Elaine G. Ramsey, husband and wife. in fee. TAX MAP PARCEL NUMBER: 11-07-0495-016A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AFFIDAVIT OF SERVICE The Huntingdon National Bank VS. Christopher A. Ramsey and Elaine G. Ramsey Comm~onrrealt:h of Pennsylvania County of Dauphin ss. CASE NO.: 12-5214 ~-.,_. ~~.. 4..vJ r 1 ~. ~.. ;=, _~ ....«. ~ .. _ _ ---ar /'l - ~ ~. .. --~. R ~.... -° . I, John Shinkowsky, a competent adult, being duly sworn according to law, depose and say that at 1:14 PM on 11/07/2012, I served Christopher A. Ramsey at 85 Sawmill Road ,Newburg, PA 17240 in the manner described below: ^ Defendant(s) personally served. J Adult family member with whom said Defendant(s) reside(s). Relationship is Elaine . Ramc Y~ Spouse. Adult in charge of Defendant(s) residence who refused to give name and/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. Other: an officer of said Defendant's company. a true and correct copy of Notice of Sheriff s Sale of Real Property issued in the above captioned matter. Description: Sex: Female -Age: 38 -Skin: White -Hair: Blonde -Height: 5' 06" -Weight: 155 Swo to X / 4~~ and sub ~ib~d b fore me on ~t~ is John inkowsky --0--1! day of ~ ~ Y 20 AOSS 1 Huntington Quadra e, Suite 2504 Melville, NY 11747 NOT Y PUBLT (516) 284-5850 T1K!FAt-TH OF PENNCVi veur~ ' ' ~. - ' _ ., ,; r ~ , ;1" , Kathryn S. Fogle, Notary Public 1=owter Paxton Twp, Dauphin County M conµmission ex Tres Au st 13, 2016 Atty File#: 37514 -Our File# 22828 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAS>~iOt;~2-5214 :. 4- AFFIDAVIT OF SERVICE . ._ ~ w,~ ~ ; ~ ``~ ~.:,~~ -- The Huntingdon National Bank `-~;;.~ ~ <°~~ ---; r .~' ~ ~:~ ~' C"x -- .~~.' ~.~ ~;. Christopher A. Ramsey and ~, ~ =~ -' ` Elaine G. Ramsey `~'~ ~ Comrnonxealth of Pennsylvania County of Dauphin ss. I, John Shinkowsky, a competent adult, being duly sworn according to law, depose and say that at 1:14 PM on 11/07/2012, I served Elaine G. Ramsey at 85 Sawmill Road ,Newburg, PA 17240 in the manner described below: ® Defendant(s) personally served. a Adult family member with whom said Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s) residence who refused to give name and/or relationship. Manager/Clerk of place of lodging in which Defendants} resides}. Agent or person in charge of Defendant's office or usual place of business. Other: an officer of said Defendant's company. a true and correct copy of Notice of Sheriff s Sale of Real Property issued in the above captioned matter. Description: Sex: Female -Age: 38 -Skin: White -Hair: Red -Height: 5' 06" ;Weight: 155 Swq~{~ to and sub cis, ribe before me' on ~is ~~ day of QYil,rn ,~' 201 NOTARY PUB I corvwtoriweAl,~rh ur PI:N~sYI,vAMA NOTARIAL SEAL Kathryn 5. Pogle, Notary Public Lower Paxton Twp, Dai~hin County `' - • `M commission ex Tres Au st 13, 2016 X // /1 / / Johrit- inkowsk¢ AOSS 1 Huntington Quadr n e, Suite 2504 Melville, NY 117 (516) 284-5850 Atty File#: 37515 -Our File# 22$29 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~~~~~y` ~`-~ CASE NO.: 12-5214 AFFIDAVIT OF SERVICE The Huntingdon National Bank ~-~ - vs. , .,~ ...~ Christopher A. Ramsey and .-, ~~. ~ ~- Elaine G. Ramsey -~~ ~.. ~. ~ `- - - / 3 ._. Commonwealth of Pennsylvania ~- ~`- ~' r=~ County of Dauphin ss. -~ ~: •• ~; t`~`'..~- I, John Shinkowsky, a competent adult, being duly sworn according to law, depose and say that at 1:14-~M~i 11/07/2012, I served Elaine G. Ramsey at 85 Sawmill Road ,Newburg, PA 17240 in the manner described below: Defendant(s) personally served. Adult family member with whom said Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s) residence who refused to give name and/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. ^ Other: an officer of said Defendant's company. a true and correct copy of Notice of Sheriff s Sale of Real Property issued in the above captioned matter. Description: Sex: Female -Age: 38 -Skin: White -Hair: Blonde -Height: 5' 06" -Weight: 155 x Sw to and sub r be before me on t is John inkowsky ~~ day of ~~Cm~~r 20I~ AOSS 1 Huntington Quadrangle Suite 2504 1/n~~~~ ~ `1~ Melville, NY 11747 J~,1 J (516) 284-5850 I C ~ ~ c:umIMONWEALTH OF P1~]i115YLVANLa1 N~~ ~ Atty File#: 37515 - Our File# 22829 Kathryn S. Fogle, Notary Public Lower Paxton Twp, Dauphin County M commission ex Tres August 13, 2016 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 1.9109 (215) 790-1010 The Huntington National Bank Plaintiff Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY V. Christopher A. Ramsey and Elaine G. Ramsey No. 12-5214 Defendants AFFIDAVIT AS TO MILITARY SERVICE t, r rrn Z cO vC z C N 0 ryl (V C.0 ut Catherine Bradford, being of lawful age and being first duly sworn on oath, states and deposes as follows: I am a Legal Assistant at McCabe, Weisberg & Conway, P.C. G] , ?s On the. I Zt? day of?--6e; 2012, I personally conducted an online search through the Department of Defense Manpower Data Center at https://www.dmdc.osd.mil/scra/owa/home, which indicated that the defendants, Christopher A. Ramsey and Elaine G. Ramsey were not in the military service of the United States as of the date I conducted the search. A true and accurate copy of the printout of the online search results from the Department of Defense Manpower Data Center is attached hereto. 3. To my knowledge, defendants, Christopher A. Ramsey and Elaine G. Ramsey, are not infants or incompetent. I affirm, under the penalties for perjury, that the foregoing representations are true. SWORN AND SUBSCRIBED r BEFORE ME THIS DAY By: tia c?xC, e. Name: Catherine Bradford OF 2012 NOT Maleek-1h V t La S A L r"s-I)+otary Public Cit/ ut Philadelphia, Philadelphia COVnty MY COMMISSION EXPIRES APR, 06, 2015 Department of Defense Manpower Data Center Status RepoTt Pursuant to Servicemembers, Civil Relief Act Last Name: RAMSEY First Name: Middle Name: Active Duty Status As Of: Dec-12-2012 Results as of : Dec-12-2012 09:14:10 SCRA 2.3 On Active Duty On Active Duty Status Date Active. Duty Start Date - Active Duty End Date Status Service Component NA NA No NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the Individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 at seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Maine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: H3ILPLKV49 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Huntington National Bank Plaintiff Attorneys for Plaintiff Z C n p tN Co r --, -G . COURT OF COMMON PLEAS CUMBERLAND COUNTY V. Christopher A. Ramsey and Elaine G. Ramsey No. 12-5214 Defendants Praecine to Substitute Nunc Pro Tunc TO THE PROTHONOTARY: Kindly substitute the attached (1) Affidavit of Non-Military Service and Certification in place of the Affidavit of Nan-Military Service and Certification that were filed with the court on October 19, 2012 as part ofthe judgment package in the above-captioned case. The affidavit of Non-Military service and Certification that were filed on October 19, 2012 were true and correct at the time of filing and remain true today however the document was inadvertently filed without being notorized. Accordingly said Affidavit of Non-Military Service and Certification have been re- executed and are presented herewith for substitution into the judgment package. ] nc . McCabe, Esquire [ ] erre [ Edwar . Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ J Heidi R. Spivak, Esquire [ J Brian T. LaManna, Esquire ( ] Kevin T. McQuail, Esquire [ 1 Marc S. Weisberg, Esquire a[i] Margaret Gairo, Esquire [ J Joseph F. Riga, Esquire [ ] Marisa J. Cohen, Esquire [ ] Ann E. Swartz, Esquire ( ] Christine L. Graham, Esquire Attorneys for Plaintiff The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 at seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defense link. mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(9 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: JIEJL91MKD The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.milifaq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: ;1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (.ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: H3ILPLKV49 Department of Defense Manpower Data Center status Repcwt Pmuant to Servicememben Civil Relief Act Last Name: RAMSEY First Name: Middle Name: Active Duty Status As Of: Dec-12-2012 Results as of : Dec-12-2012 09:15:35 SCRA 2.3 On Active. Duty On Active Duty Status Date Active Duty. Start Data Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HislHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the Individual or his/her unit has received early no5flcation to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This Status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely-Dixon, Director Department of Defense Manpower Data Center 4800 Mark Center Drive„ Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 at seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: JIEJL91MKD SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson C7 Sheriff ofsraric Jody S Smith r Chief Deputy 2 ' AIL 23 (o: Richard W Stewart ^ CUMBERLAND Solicitor OFFICE 9F THE SHERIFF PEW4S 1 LVAMA The Huntington National Bank Case Number vs. 2012-5214 Elaine G. Ramsey (et al.) SHERIFF'S RETURN OF SERVICE 01/03/2013 01:20 PM -Deputy Ronald Hoover, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 85 Old Sawmill Drive, Newburg, PA 17240, Cumberland County. 03/05/2013 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 6/5/2013 06/05/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on June 5, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Terrance McCabe, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $1,388.58 SO ANSWERS, July 01, 2013 RONW R ANDERSON, SHERIFF sa5-pd , C . 9,3sz)e (c),CountySuite Slieriff,Teleosoft,Inc. McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET CAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 123 South Broad Street,Suite 2080 Philadelphia,Pennsylvania 19109 215 790-1010 The Huntington National Bank CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 12-5214 Christopher A.Ramsey and Blaine G.Ramsey Defendants AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at: 85 Old Sawmill Drive,Newburg,Pennsylvania 17240, as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Christopher A. Ramsey 85 Old Sawmill Drive Newburg,Pennsylvania 17240 Elaine G.Ramsey 85 Old Sawmill Drive Newburg,Pennsylvania 17240 2. Name and address of Defendants in the judgment: Name Address Christopher A.Ramsey 85 Old Sawmill Drive Newburg,Pennsylvania 17240 Elaine G.Ramsey 85 Sawmill Road Newburg,Pennsylvania 17240 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 Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 85 Old Sawmill Drive Newburg,Pennsylvania 17240 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8th Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor,Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 t J + PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 1.7128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland'County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept of Justice,Room 51.11 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge ----..~1`-- or information and belief. I understand that false statements-herein are ma u 'ect to th penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification-to-authorities. Lo 17,5 11// Joseph F. ' a,Esqui DATE Attorney for Plain LEGAL.DESCRIPTION RB5678 85 Old Sawmill Drive,Newburg,Pennsylvania 17240. ALL THAT CERTAIN lot or tract of land,together with improvements erected thereon,known and designated as Lot No. I on the hereinafter referred to subdivision plan,situate in Hopewell Township,Cumberland County, Pennsylvania,bounded and described as follows: BEGINNING at a concrete monument set at the northwesterly most corner of the within described lot and set in line of lands now or formerly of John J. Clippinger;thence along line of lands now or formerly of John J. Clippinger, North 61 degrees 39 minutes 20 seconds East,277.05 feet to an existing stub in stones,the corner of the within described lot and corner of lands now or formerly of George A.Hoover;thence along line of lands now or formerly of George A.Hoover,South 24 degrees 53 minutes 14 seconds East, 50993 feet to an iron pin in line of lands now or formerly of Pennsylvania Turnpike Commission;thence along line of lands.now or formerly of Pennsylvania Turnpike Commission,South 76 degrees 58 minutes 13 seconds West,282.58 feet to an iron pin at corner of other lands now or formerly of Gary D.Jestes and Beverly June Glanville,now Beverly June Hardy;thence by Lot No.2 as shown on the aforesaid plan,North 24 degrees 53 minutes 14 seconds West,435.15 feet to the point and place of BEGINNING. CONTAINING a total area of 3.000 acres. The above description is in accordance with subdivision plan entitled"Land Subdivision for Lucy E.Jestes"recorded August 7, 1985, in Cumberland County Plan Book Volume 48,Page 18,which is intended to correct,revise and supersede the plan recorded in Plan Book Volume 41,Page 87. The above described lot is SUBJECT TO an existing 16 foot right-of-way and 50 foot wide dedicated right-of-way along the southerly property line and extending the full width of the lot. BEING the same premises which STEWART P. CRAIG AND COLLEEN RAE CRAIG by deed dated September 7, 2007 and recorded September 10,2007 in the office of the Recorder in and for Cumberland County in Deed Book Instrument No.200735112,granted and conveyed to Christopher A.Ramsey and Elaine G.Ramsey,husband and wife, in fee. TAX MAP PARCEL NUMBER: 11-07-0495-016A r McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#3071.69 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 123 South Broad Street,Suite 2080 Philadelphia,Pennsylvania 19109 '(215)790-1010 CIVIL ACTION LAW The Huntington National Bank COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Christopher A. Ramsey and Elaine G.Ramsey Number 12-5214 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To; Christopher A.Ramsey Elaine G.Ramsey 85 Old Sawmill Drive 85 Sawmill Road Newburg,Pennsylvania 17240 Newburg,Pennsylvania 17240 Your house(real estate)at 85 Old Sawmill Drive,Newburg,Pennsylvania 17240 is scheduled to be sold at Sheriffs Sale on March 6,2013 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$135,776.46 obtained by The Huntington National Bank against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to The Huntington National Bank the back payments,late charges, costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened,you may call McCabe,Weisberg and Conway,P.C. at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 1.7013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION RB5678 85 Old Sawmill Drive,Newburg,Pennsylvania 17240. ALL THAT CERTAIN lot or tract of land,together with improvements erected thereon,known and designated as Lot No. I on the hereinafter referred to subdivision plan,situate in Hopewell Township,Cumberland County, Pennsylvania,bounded and described as follows: BEGINNING at a concrete monument set at the northwesterly most corner of the within described lot and set in line of lands now or formerly of John J. Clippinger;thence along line of lands now or formerly of John J.Clippinger, North 61 degrees 39 minutes 20 seconds East,277.05 feet to an existing stub in stones,the corner of the within described lot and corder of lands now or formerly of George A.Hoover;thence along line of lands now or formerly of George A.Hoover, South 24 degrees 53 minutes 14 seconds East,509.93 feet to an iron pin in line of lands now or formerly of Pennsylvania Turnpike Commission;thence along line of lands now or formerly of Pennsylvania Turnpike Commission, South 76 degrees 58 minutes 13 seconds West,282.58 feet to an iron pin at corner of other lands now or formerly of Gary D.Jestes and Beverly June Gianville,now Beverly June Hardy;thence by Lot No.2 as shown on the aforesaid plan,North 24 degrees 53 minutes 14 seconds West,435.15 feet to the point and place of BEGINNING. CONTAINING a total area of 3.000 acres. The above description is in accordance with subdivision plan entitled "Land Subdivision for Lucy E.Jestes"recorded August 7, 1985,in Cumberland County Plan Book Volume 48,Page 18,which is intended to correct,revise and supersede the plan recorded in Plan Book Volume 41,Page 87. The above described lot is SUBJECT TO an existing 16 foot right-of-way and 50 foot wide dedicated right-of-way along the southerly property line and extending the full width of the lot. BEING the same premises which STEWART P.CRAIG AND COLLEEN RAE CRAIG by deed dated September 7, 2007 and recorded September 10,2007 in the office of the Recorder in and for Cumberland County in Deed Book Instrument No.200735112,granted and conveyed to Christopher A.Ramsey and Elaine G.Ramsey,husband and wife, in fee. TAX MAP PARCEL NUMBER: 11-07-0495-016A WRIT OF EXECUTION and/or ATTACHMENT COMMONZWEALTH OF PENNSYLVANIA) NO. 12-5214 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE HUNTINGTON NATIONAL BANK Plaintiff(s) From CHRISTOPHER A.RAMSEY AND ELAINE G.RAMSEY (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $135,776.46 L.L.: .50 Interest from 10/12/12 TO 3/6/13$3,258.72 AT$22.32 PER DIEM Atty's Comm: % Due Prothy:$2.25 Arty Paid: $215.25 Other Costs: Plaintiff Paid: Date: 10/26/12 David Buell,Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: JOSEPH F.RIGA,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 TRUE COPY FROM RECORD In Testimony whereof,1 here unto set my hand and the Wal of said Co rt rtwarlisle,Pa.' "o a "-a 1/13 This atf day of I�X '20 rothoonotary On October 31, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Hopewell Township, Cumberland County, PA, Known and numbered as, 85 Old Sawmill Drive, Newburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 31, 2012 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2012-5214 Civil ume 48, Page 18,which is intended to correct,revise and supersede the The Huntington National Bank plan recorded in Plan Book Volume 41,Page 87. vs. The above described lot is SUB- Elaine G. Ramsey, JECT TO an existing 16 foot right- Christopher A. Ramsey of-way and 50 foot wide dedicated Atty.:Terrance McCabe right-of-way along the southerly 85 Old Sawmill Drive, Newburg, p iope t the loand extending the full Pennsylvania 17240. BEING the same premises which ALL THA T CERTAIN lot or tract STEWART P. CRAIG AND COLLEEN of land,together with improvements RAE CRAIG by deed dated September erected thereon, known and desig- 7 2007 and recorded September 10, nated as Lot No. 1 on the hereinafter 2007 in the office of the Recorder in referred to subdivision plan, situate and for Cumberland County in Deed in Hopewell Township, Cumberland Book Instrument No. 2007351 12, 'County,Pennsylvania,bounded and granted and conveyed to Christopher described as follows: A. Ramsey and Elaine G. Ramsey, BEGINNING at a concrete monu- husband and wife,in fee. ment set at the northwesterly most TAX MAP PARCEL NUMBER: 11- corner of the within described lot and 07-0495-016A set in line of lands now or formerly of John J.Clippinger;thence along line of lands now or formerly of John J. Clippinger,North 61 degrees 39 min- utes 20 seconds East,277.05 feet to an existing stub in stones,the corner of the within described lot and corner of lands now or formerly of George A.Hoover;thence along line of lands now or formerly of George A.Hoover, .South 24 degrees 53 minutes 14 seconds East,509.93 feet to an iron pin in line of lands now or formerly of Pennsylvania Turnpike Commis- sion;thence along line of lands now or formerly of Pennsylvania Turnpike Commission, South 76 degrees 58 minutes 13 seconds West, 282.58 'feet to an iron pin at corner of other lands now or formerly of Gary D. Jestes and Beverly June Gianville, now Beverly June Hardy; thence by Lot NO.2 as shown on the aforesaid plan, North 24 degrees 53 minutes 14 seconds West, 435.15 feet to the point and place of BEGINNING. CONTAINING a total area of 3.000 acres. The above description is in ac- cordance with subdivision plan en- titled"Land Subdivision for Lucy E. Jestes"recorded August 7, 1985, in Cumberland County Plan Book Vol- 93 a! J • 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: January 25, February 1, and February 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. isa Marie Coyne, 11ditor f SWORN TO AND SUBSCRIBED before me this 8 da y of February, 2013 C;Lz Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. 2020 Technology Pkwy e atr*1 o twNew s 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.DauAhin in Miscellaneous Book°M", Volume 14, Page 317. 2012-5214 Civil The Huntington National ank Vs This ad ran on the date(s)shown below: + Elaine G.Ramsey Christopher A.Ramse� ' 01/22/13 1 Arty: Terrance McCabe 01/29/13 85 old Sawmill Drive, Newburg, , c 02/05/13 Pennsylvania 17240. r ALL THAT CERTAIN lot or tract of I land,together with improvements erected thereon,]mown and designated as Lot No. 1 on the hereinafter referred to subdivision plan, situate in Hopewell Township, Cumberland County, Pennsylvania, Sworn to and ubscribed before me s 14 day of February, 2013 A.D. bounded and described as follows: BEGINNING at a concrete monument cl set at the northwesterly most comer of the within described lot and set in he of lands V I jilblic ` now or formerly of John J. clippinger, thence along he of lands now or formerly of John J. Clippinger,North 61 degrees 39 minutes 20 seconds East,277.05 feet to an existing stub in stones,the comer of the within described lot and comer COMMQNWEALTH OF PENNSYLVANIA of lands now or formerly of George A. Notarial Seal Hoover;thence along line of lands now Holly Lynn Warfel,Notary Public or formerly of George A.Hoover,South Washington Twp.,Dauphin County 24 degrees 53 minu 1d.sPC�° s East, My Commission Expires Dec.12,2016' 509.93 feet to an iron pin in line of lands MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES now or formerly of Pennsylvania Turnpike ^ mmission; thence along line of lands IS o v or formerly of Pennsylvania Ihrnpike 110rte t__ e_th 76 SA minutes i I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Federal Nationial Mtg Assoc is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2013, under and by virtue of a writ Execution issued on the 26th day of October, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 5214, at the suit of Hungtington National Bank against Christopher A &Elaine G Ramsey is duly recorded as Instrument Number 201324176. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this , day of A.D. O Recorder of Deeds Reorder of s,Cumberland County,Carlisle,PA My Commission Expires the Fast Monday of Jan.2014