HomeMy WebLinkAbout07-7436UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Credit Based Asset Servicing and COURT OF COMMON PLEAS
Securitization, LLC ; CIVIL DIVISION
4828 Loop Central Drive
Houston, TX 77081-2226 :Cumberland County
Plaintiff
v.
Leroy M. Pomraning /?
Dorothy R. Pomraning NO. 0'7-- '7q a(. O-ivi t term
Keith Pomraning
298 McAllister Church Road
Carlisle, PA 17013
De f endant (s)
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty (20)
days after this Complaint and Notice are served, by entering a written
appearance personally or by attorney and filing in writing with the Court
your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice
for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD
TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9180
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO'IMMEDIATAMENTE, SI NO TIENE ABOGADO
O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify
us in writing of a dispute within the 30 day period, we will obtain verification of the debt or
a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not
an admission of liability on your part. Also, upon your written request within the 30 day
period, we will provide you with the name and address of the original creditor if different from
the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. If Plaintiff is an assignee then it
is such by virtue of the following recorded assignments:
Assignor: Madison Equity Corporation
Assignments of Record to: Madison Equity LLC
Recording Date: 7/24/06 Book: 728 Page: 5043
Assignor: Madison Equity LLC
Assignee: Credit Based Asset Servicing and Securitization, LLC
Recording Date: LODGED FOR RECORDING
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 298 McAllister Church Road
MUNICIPALITY/TOWNSHIP/BOROUGH: West Pennsboro Township
COUNTY: Cumberland
DATE EXECUTED: 7/12/06
DATE RECORDED: 7/24/06 BOOK: 1959 PAGE: 2175
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said mortgage as of
12/10/07:
Principal of debt due $274,414.71
Unpaid Interest at 12.49%*
from 4/1/07 to 12/10/07
(the per diem interest accruing on
this debt is $93.90 and that sum
should be added each day after
12/10/07) 23,788.62
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $0 and that sum should
be added on the first of each
month after 12/10/07) 3,603.27
Late Charges
(monthly late charge of $146.64
should be added in accordance
with the terms of the note
each month after 12/10/07) 1,026.48
Late Charge Credit (586.56)
BPO 200.00
Attorneys Fees (anticipated and actual
to 5% of principal) 13,720.74
TOTAL $316,772.26
This interest rate is subject to adjustment as more fully set
forth in the Note and mortgage.
7. The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be collected
in the event of a third party purchaser at Sheriff's Sale. If the
mortgage is reinstated prior to the sale, reasonable attorney's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A", and made part
hereof, and defendant(s). have failed to proceed within the time
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $316,772.26 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
UDREN JAW OFFICES, P.C.
BY _ZJVLL4&4=:K_
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
ALL THAT CERTAIN TRACT OF LAND SITUATE IN WEST PENNSBORO TOWNSHIP, CUMBERLAND
COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT A POINT AT THE INTERSECTION OF THE CENTER LINE OF L.R 21091 AND TOWNSHIP
ROAD 482 ALSO KNOWN AS GOOD HOPE ROAD; THENCE ALONG THE CENTER LINE OF GOOD HOPE ROAD
SOUTH FIVE DEGREES NINE MINUTES WEST THREE HUNDRED TWENTY
FEET TO A NAIL SET IN THE CENTER LINE OF GOOD HOPE ROAD; THTWO AND EIGHT ENCE LEAVING NTHE CE TERR LIKE
OF GOOD HOPE ROAD NORTH EIGHTY FIVE DEGREES TWENTY FOUR MINUTES WEST THREE HUNDRED SIXTY
NINE AND TWENTY NINE HUNDREDTHS FEET TO A POINT AT OTHER LAND SNOW OR FORMERLY OF CHARLES
J RIFE, OF WHICH THIS WAS ONCE A PART; THENCE ALONG SAME NORTH ZERO DEGREES TWENTY THREE
MINUTES WEST TWO HUNDRED EIGHTY NINE AND THIRTY HUNDREDTHS FEET TO A NAIL SET AT THE
CENTER LINE OF L.R 21091 AFORESAID; THENCE ALONG SAME NORTH .EIGHTY NINE DEGREES THIRTY
SIX MINUTES FIFTY SWIEN SECONDS EAST THREE HUNDRED NINETY NINE AND THREE HUNDREDTHS FEET
TO THE POINT AND PLACE OF SEGINNING.
P.
October 29, 2007
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
The HOMEOWNEROS MORTGAGE ASSISTANCE PROGRAM ( EMA4 risky bg nhh-
to help to save your home- This Notice explains how the prngram works
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact an attorney in your area. The local bar association may be able
to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES
SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
OHOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
EXHIBIT A
Page 1 of 1
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER:
Leroy M. Pomraning
Dorothy R. Pomraning
_Keith Pomraning._....._.__....._..__._.__....._._...._.__....._....._.....___....._._._......---......_..__......_...._....._
298 McAllister Church Road
Carlisle. PA17013....._._._..... _........... ............. _._...........
_30236889 ....___.....___.....__._..._..._._..__._....._._......__._..__....._.:._....__......__.._......__._......_..._....._...._....._...
Madison Equit ._Cgj:po_ration_._.......... _.... ___..... _.._.....__._....._..__......___.....
__._.....__
Credit Based Asset
HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM
WHICH CAN SAVE. VOTTR HOME. FROM FORECLOSURE AND
HF.i.P VOIT MAKE. FITTITRF. MORTGAGF, PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE OACTO), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary
stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that
time you must arrange and attend a Oface-to-faceO meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
THE, NEXT (30) DAYS_ IF YOU DO NOT APPLY FOR FMFRGFNC'.Y MORTGAC F
ASSISTANCE, YOT T MT 1ST BRING YOT TR MORTGACM I TP TO DATE. THE PART OF THIS
NOTTCF. CAT.T,FT) OHOW TO CT TRF. You g MORTCrAap T)F.FAT TT.TO F.XPT.ATNS HOW TO
CONSITMFR CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer
credit counseling agencies listed at the end of this notice, the lender may NOT take action against
you for thirty (30) days after the date of this meeting. The names, addresses and telenhnne numhers
of designated consumer credit counseling a?uencie., fnr the county in which the n=erty is located
are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting.
Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE. ASSISTANCE. - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature
of your default.) If you have tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies
listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing
Page 2 of 2
Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your
face- to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO
COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
NATURE. OF THE. DEFAULT - The MORTGAGE debt held by the above lender on your property
located at:
298 McAllister Church Road
Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
Monthly Payments of $2932.83 for May 1,2007 through June 1,2007 = $5865.66
Monthly Pa eats „of $3683.51 for July-1,2007 through October, 1. 2007 $14734.04_...._.._.._._.__.....__._....
_._Montl y_Late_Cbarges "46.64_for_M4 1_,2007 through October 1,2007, _=...$879.84_...._.... ....... _.__....._._._...
Other charges (explain/itemize): _Escrow ..Advance_=$3603Z7_,_...,._.__......_..._......__....____....____....._...._...._...._.....__._....._.._.._.
TOTAL AMOUNT PAST DUE: S25ns2.xt
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not annlicahle): NA
HOW TO CITRF. THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS %2S0R2_R1 PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments must he made either by emb, cashier's check, certified check or money order made payahl
and sent to,
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter: (Do not use if not amlicahle_l: WA
Page 3 of 3
IF YOU DO NOT CURE THE. DEFAULT -- If you do not cure the default within THIRTY (30) DAYS
of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage. debt, This
means that the entire outstanding balance of this debt will be considered due immediately and you may lose
the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
foreclnse upon pnur martg2ged prnn
IF THE. MORTGAGE. IS FORECLOSED ITPON - The mortgaged property will be sold by the Sheriff
to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency
before the lender begins legal proceedings against you, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against
you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed
$50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other
reasonable costs. If you cure h default wi h*n the THIRTY (30) DAY period, you will not he
required to pay's fees-
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without
your having reaffirmed it, then lender cannot pursue this remedy.
RIGHT TO CURE. THE, DEFAULT PRIOR TO SHERIFF'S SALF. - If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to
paying the total amount hen pact due, i lus any late or other charges then due, reasonable attorney's fees and
costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as ecified
in writing by the lender and hyj erforming aji t other requirements under the mortgage. Curing your
default in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
F.ARi LEST POSSIBLE SHERIFF'S SALE DATE. - It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from
the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment or action will be by contacting the lender.
Name of Lender/Servicer: Litton Loan Serycng
Address: 4828 Loop Central Drive
Suite 51
_Houston, _TX 77081_....._..._........ __....__.__. _.
..................................... .......... ........................_.._........._...._...._._._................
.
Phone Number: 1-800-999-8501
_...... _.......... __.._..... _.... ....... _............ __......... ..... ....... _...........
Fax Number: 1-713-966-8906
Contact Person: Default Administration..De
EFFECT OF SHERIFF'S SAi.E. - You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE. - You may not transfer your home to a buyer or transferee who will
assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs
are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
Page 4 of 4
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
Page 5 of 5
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CCCS of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
FAX (717) 5414670
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
Community Action Comm of the Capital Region
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
FAX (717) 234-2227
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
FAX n/a
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St.
Gettysburg, PA 17325
(717) 334-1518
FAX (717) 334-8326
Page 6 of 6
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Litton Loan Servicing LP
P.O. Box 9010
Temecula, CA 92589-9010
Send Payments To.
Litton Loan Servicing LP
Attn: Cash Management Department
P.O. Box 4387
Flouston, TX 77210-4387
Send Correspondence To:
Litton Loan Servicing LP
Attn: Cu atomer Assistance Response Team
4828 Loop Central Drive
Houston, TX 77081
2204251586
LEROY POMRANING
298 MCALLISTER CHURCH RD
CARLISLE, PA 17015
PRESORT
First-Class Mail
U.S. Postage and
Fees Paid
WSO
20070711-80
N
T- Litton
Loan Servicingo
7/10/2007
LEROY POMRANING
298 MCALLISTER CHURCH RD
CARLISLE, PA 17015
ACT 91 NOTICE
4828 Loop Central Drive
Houston, TX 77081
Telephone (800) 999-8501
Fax (713) 966-8906
www.littonloan.com
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official Notice that the mortgage on your home is in default. and the lender intends to foreclose
Specific information about the nature of the default is provided in the attached naves
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HE_M V may be able to
heb save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
wrrBON 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the
Counseling Agency.
The name, address, and phone number of Consumer Credit Counseling Agencies serving vour County are
listed at the end of the Notice. If von have any questions von may call the Pennsvlvania Housing Finance
Auencv toll-free at (800) 342-2397 Perso _ wi h i paired hearing can call rl7 71 7W sup
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUXERO MENCIONADO
ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE
SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDI IIR SU HIPOTECA.
EA. 'il
HOMEOWNER'S NAME(S): Leroy Pomraning
Keith Pomraning
PROPERTY ADDRESS: 298 Mcallfister Church Road
CarlWe, PA 17013
LOAN ACCT. NO.: 30236889
ORIGINAL LENDER: Contact Litton Loan Servicing LP
CURRENT LENDERISERVICER: Litton Loan Servicing LP
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a
"face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS
MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS
NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT," EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUME CREDIT COUNSELING AGENCUS - If you meet with one of the consumer credit counseling
agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the
date of this meeting. The names, addresses, and telephone numbers of designated consumer credit counseling
amencies for the county in which the nronerty is located are set forth at the end of this Notice. It is only necessary to
schedule one "face-to-face" meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later
in this Notice (see following pages for specific information about the nature of your default). If you have tried and
are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the
Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign, and file a completed
Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.
Your application MUST be filed or postmarked within thirty (30) days of your "face-to-face" meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed
by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has
sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings
will be pursued against you if you have met the time requirements set forth above. You will be notified directly by
the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have Sled bankruptcy, you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brim it uu to date.)
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at:
298 Mcallister Church Road
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
5/112007 through 7/1/2007 at $2,933.00 totaling $8,798.00
Other charges Labe charges $293.28
Deferred late charges $0.00
NSF charges $0.00
Deferred NSF charges $0.00
Suspense balance $0.00
TOTAL AMOUNT DUE AS OF THIS DATE $9,842.45
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: Cure the default.
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this
Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $9,942.45 PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments must be made either by cashier's check, certified check, or money order made payable
and sent to:
Litton Loan Servicing LP
Attention: Cash Management Department
P.O. Box 4387
Houston, TX 77210-4387
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date
of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the
entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the
mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged
property.
IF THE MOR A F T FORECLOSE PON - The mortgaged property will be sold by the Sheriff to pay off
the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender
begins legal proceedings against you, you will still be required to pay the reasonable attorney's fee that were actually
incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the
amount you owe the lender, which may also include other reasonable costs. If you cure the default within the
THIRTY (30) DAY period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all
other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SEIER7FF'S SALE - If you have not aced the default within
the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to one the default
and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount
then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the
foreclosure sale, and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by
performing any other requirements under the mortgage. Curing your default in the manner set forth in this
Notice will restore your mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such Sheriffs Sale
of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A
Notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to
one the default will increase the longer you wait. You may find out at any time exactly what the required payment
or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: LITTON LOAN SERVICING LP
Address: 4828 Loop Central Drive, Houston, TX 77081
Phone Number: (800) 999-8501
Fax Number: (713) %6-8906
Contact Person: Default Administration Department
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a
lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - Under the terms of your mortgage and note, it may be possible to sell or
transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the
mortgage are satisfied.
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CUMBERLAND COUNTY
Acorn Housing Adams County Interfaith
14 S. 13th Street Housing Authority
Harrisburg, PA 17104 40 E High Street
717.213.0150 Gettysburg, PA 17325
717.334.1518
Community Action Loveship, Inc.
Commission of Captial 2320 North 5th Street
Region Harrisburg, PA 17110
1514 Derry Street 717.232.2207
Harrisburg, PA 17104
717.232.9757
PHFA
211 North Front Street
Harrisburg, PA 17110
T17.780.3940
800.342.2397
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Maranalha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
r?^^?
Litton Loan Servicing LP
P.O. Box 9010
Temecula, CA 92589-9010
Send Payments To:
Litton Loan Servicing LP
Attn: Cash Management Department
P.O. Banc 4387
Flouston, TX 77210-4387
Send Correspondence To:
Litton Loan Servicing LP
Attn: Customer Assistance Response Team
4828 Loop Central Drive
Houston, TX 77081
2204251587
II I I I I I I I I I I I I InI I I I I II II II II I I II II IIIInIIIIII I I I I I I I I I nIII
KEITH POMRANING
298 MCALLISTER CHURCH RD
CARLISLE, PA 17015
PRESORT
First-Class Mail
U.S. Postage and
Fees Paid
WSO
20070711-80
L
011 Litton Loan Servicing
7{10/2007
KEITH PONU AMNG
298 MCALLISTER CHURCH RD
CARLISLE, PA 17015
ACT 91 NOTICE
4828 Loop Central Drive
Houston, TX 77081
Telephone (800) 999-8501
Fax (713) 966-8906
www.littonloan.com
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an oMdal Notice that the mortgage on your home is in default, and the lender intends to foreclose.
SpecMc information about the nature of the default is provided in the attached eases.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMMAP) may be able to
help save your home. This Notice explains how the Drop-ram works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the
Counseling Agency.
The name, address. and phone number of Consumer Credit Counseling Agencies serving your County are
listed at the end of the Notice. If you have any auestions, you may call the Pennsylvania Housing Finance
Agency toII-free at (800) 342-2397. Persons with inm d hearing can ran (717) 71869,
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you ilnd a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION ENMEDIATAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE
SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDEVI R SU HIPOTECA.
HOMEOWNER'S NAME(S): Keith Pomraning
Leroy Pomraning
PROPERTY ADDRESS: 298 Mcallister Church Road
Carlisle, PA 17013
LOAN ACCT. NO.: 30236889
ORIGINAL LENDER: Contact Litton Loan Servicing LP
CURRENT LENDERISERVICER: Litton Loan Servicing LP
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE -ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a
"face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS
MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS
NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT," EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling
agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the
date of this meeting. The names, addresses, and televhone numbers of designated consumer credit counseling
agencies for the county in which the oroverty is located are set forth at the end of this Notice. It is only necessary to
schedule one "face-to-face" meeting. Advise your lender immediately, of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later
in this Notice (see following pages for specific information about the nature of your default). If you have tried and
are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the
Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign, and file a completed
Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.
Your application MUST be filed or postmarked within thirty (30) days of your "face-to-face" meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW THE OTHER TIM PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available fiords for emergency mortgage assistance are very limited. They will be disbursed
by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has
sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings
will be pursued against you if you have met the time requirements set forth above. You will be notified directly by
the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT TIM DEBT.
(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT Brim it up to date.)
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at:
298 Mcallister Church Road
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
51112007 through 7/1/2007 at $2,933.00 totaling $8,798.00
Other charges Late charges $293.28
Deferred late charges $0.00
NSF charges $0.00
Deferred NSF charges $0.00
Suspense balance $0.00
TOTAL AMOUNT DUE AS OF THIS DATE $9,842.45
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: Cure the default.
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this
Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $9,842.45 PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments must be made either by cashier's check, certified check, or money order made payable
and sent to:
Litton Loan Servicing LP
Attention: Cash Management Department
F.O. Box 4387
Houston, TX 77210-4387
IF YOU O N CURE. THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date
of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the
entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the
mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged
property-
IF THE MORTGAGE IS FORECLOSED ICON - The mortgaged property will be sold by the Sheriff to pay off
LL the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender
:?•, _. begins legal proceedings against you, you will still be required to pay the reasonable attorney's fee that were actually
incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the
amount you owe the lender, which may also include other reasonable costs. If you cure the default within the
THIRTY (30) DAY period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all
other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SEMRI + F'S SALE - If you have not aped the default within
the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default
and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount
then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the
foreclosure sale, and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by
performing any other requirements under the mortgage. Curing your default in the manner set forth in this
Notice will restore your mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such Sheriffs Sale
of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A
Notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of cease, the amount needed to
cure the default will increase the longer you wait. You may find out at any time exactly what the required payment
or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: LITTON LOAN SERVICING LP
Address: 4828 Loop Central Drive, Houston, TX 77081
Phone Number: (800) 999-8501
Fax Number- (713) 966-8906
Contact Person: Default Administration Department
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a
lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - Under the terms of your mortgage and note, it may be possible to sell or
transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the
mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CUMBERLAND COUNTY
Aoom Housing
14 S. 13th Street
Harrisburg, PA 17104
717.213.0150
Adams County Interfaith
Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2001) 1-Inglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action
Commission of Capital
Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranathe
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
V E R I F I C A T I O N
The undersigned, hereby states that he/she is the attorney for
the Plaintiff, a corporation unless designated otherwise; that
he/she is authorized to take this Verification and does so because
of the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he/she
has personal knowledge of some of the facts averred in the
foregoing pleading; and that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge,
information and belief and the source of his information is public
records and reports of Plaintiff's agents. The undersigned
understands that this statement herein is made subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
UDREN LAW OFFICES, P.C.
(1/?lLlc-!it/l/?C.e/« !
BY: ( ALL"
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
rya ?
0
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-07436 P
0 r
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CREDIT BASED ASSET SERVICING
VS
POMRANING LEROY M ET AL
SHANNON SHERTZER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
the
POMRANING LEROY M
was served upon
DEFENDANT
, at 1336:00 HOURS, on the 28th day of December , 2007
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
LEROY POMRANING
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
.00
.00
10.00
.00
28.00
Sworn and Subscibed to
before me this
day
of
So Answers:
R. Thomas Kline
12/28/2007
UDREN LAW OFFICES
By;
Deputy eriff
A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-07436 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CREDIT BASED ASSET SERVICING
VS
POMRANING LEROY M ET AL
SHANNON SHERTZER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
POMRANING DOROTHY R
the
DEFENDANT , at 1336:00 HOURS, on the 28th day of December-, 2007
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
DOROTHY POMRANING
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
)164j07 C ? 16.00
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline 4]
12/28/2007
UDREN LAW OFFICES
By.
Deputy Sheriff
of A. D.
SHERIFF'S RETURN - REGULAR
CASE 40
r : 2007-07436 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CREDIT BASED ASSET SERVICING
VS
POMRANING LEROY M ET AL
SHANNON SHERTZER
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
POMRANING KEITH
DEFENDANT
the
at 1336:00 HOURS, on the 28th day of December , 2007
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
KEITH POMRANING
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
r% r%
/ l V . V V
Sworn and Subscibed to
before me this
day
So Answers:
R. Thomas Kline
12/28/2007
UDREN LAW OFFICES
By:
Deputy STieriff
of A. D.
w
I `.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Credit Based Asset Servicing :COURT OF COMMON PLEAS
and Securitization, LLC :CIVIL DIVISION
Plaintiff :Cumberland County
V.
Leroy M. Pomraning
Dorothy R. Pomraning :NO. 07-7436 CIVIL TERM
Keith Pomraning
Defendant(s)
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification for the
Verification attached to the Complaint in Mortgage Foreclosure with
regard to the captioned matter.
DATED: January 29, 2008
LAW 0,PFICES, P.C.
BY:
Attoiyeyys for -Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
,-'ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
c
V E R I F I C A T 1 0 N
The undersigned, an officer of the Corporation which is the
Plaintiff in the foregoing Complaint or an officer of the
Corporation which is the servicing agent of Plaintiff, and being
authorized to make this verification on behalf of the Plaintiff,
hereby verifies that the facts set forth in the foregoing Complaint
are taken from records maintained by persons supervised by the
undersigned who maintain the business records of the mortgage held
by Plaintiff in the ordinary course of business and that those
facts are true and correct to the best of the knowledge,
information and belief of the undersigned.
The undersigned understands that this statement is made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: le?bt ??1 moo?
Leroy M. Pomraning
Dorothy R. Pomraning
Keith Pomraning
Loan #30236889
MJV #07080453
Name : - enise Bailey
Title: Assistant F-ccretary
Company:
LITTON LOAN SERVICING LP
i
p_.3
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID # 45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Credit Based Asset Servicing :COURT OF COMMON PLEAS
and Securitization, LLC :CIVIL DIVISION
4828 Loop Central Drive :Cumberland County
Houston, TX 77081-2226
Plaintiff :MORTGAGE FORECLOSURE
V.
Leroy M. Pomraning :NO. 07-7436 CIVIL TERM
Dorothy R. Pomraning
Keith Pomraning
298 McAllister Church Road
Carlisle, PA 17013
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
Defendant (s) Leroy M. Pomraning, Dorothy R. Pomraning and Keith Pomraning
for failure to file an Answer to Plaintiff's Complaint within 20 days
from service thereof and for foreclosure and sale of the mortgaged
premises, and assess Plaintiff's damages as follows:
As set forth in Complaint $316,772.26
Interest Per Complaint 4,659.00
From 12/11/07 to 1/29/08
Late charges per Complaint 293.28
From 12/11/07 to 1/29/08
TOTAL $321,760.54
I hereby certify that (1) the addresses of the Plaintiff and
Defendant are as shown above, and (2) that notice has been given in
accordance with Rule 237.1, a copy of whicYyi"s tacked hereto.
CES, P. C.
BY:
Atto s fo °-Plaintiff
MARK J. T--ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
/ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE :
PRO P HY
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM
IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A
DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
ar sgwre
Stuart Winneg, Esquire
Loraine Doyle, Esquire
Alan M. Minato, Esquire
Chandra M. Arkema, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. NINATO, ESQUIRE - ID #75860
CHANDRA M. ARKENA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
plipadingaQudren_rnm
Credit Based Asset Servicing and Securitization, LLC
Plaintiff
V.
Leroy M. Pomramn,#
Dorothy R. Pomraning
Keith Pomraning
Defendant(s)
TO: Leroy M. Pomraning
298 McAllister Church Road
Carlisle, PA 17013
DATE of Notice: January 18, 2008
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 07-7436 Civil Term
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES
OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD
TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRMA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE
UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN
NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR
SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS,
IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE
SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM
IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A
DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
Stuart Winneg, Esquire
Lorraine Doyle, Esquire
Alan M. Minato, Esquire
Chandra M. Arkema, Esquire
Woodcrest Corporate Center
1 I I Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINZ DOYLE, ESQUIRE - ID #34576
ALAN N. KINATO, ESQUIRE - ID #75860
CHANDRA X. ARRENA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
Credit Based Asset Servicing and Securitization, LLC
Plaintiff
V.
Leroy M. Pomranin
Dorothy R. Pomramng
Keith Pomraning
Defendant(s)
TO: Dorothy R. Pomraning
298 McAllister Church Road
Carlisle, PA 17013
DATE of Notice: January 18, 2008
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 07-7436 Civil Term
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES
OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD
TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE
UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN
NECESIDAD DE COMPARARECER USTED EN COUTE O ESCUCHAR PREUBA ALGUNA, DICTAR
SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS,
IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE
SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM
IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A
DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
ar k J. , =44 c a-
Stuart uart Winneg, Esquire
Lorraine Doyle, Esquire
Alan M. Minato, Esquire
Chandra M. Arkema, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
.. . It ,
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQU:
ATTORNEY FOR PLAINTIFF
- ID #04302
- ID #45362
- ID #34576
- ID #75860
ERE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-482-6900
Credit Based Asset Servicing
and Securitization, LLC
4828 Loop Central Drive
Houston, TX 77081-2226
Plaintiff
V.
Leroy M. Pomranin$
Dorothy R. Pomraning
Keith Pomraning
298 McAllister Church Road
Carlisle, PA 17013
Defendant(s)
STATE OF
COUNTY OF
SS
THE UNDERSIGNED being duly sworn, deposes and says that the
averments herein are based upon investigations made and records
maintained by us either as Plaintiff or as servicing agent of the
Plaintiff herein and that the above Defendant(s) are not in the
military or Naval Service of the United States of America or its
Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, as amended, and that the age and last known residence and
employment of each Defendant are as follows:
Defendant:
Age:
Residence:
Employment:
Defendant:
Age
Residence:
Employment:
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO, 07-7436 Civil Term
AFFIDAVIT OF NON-MILITARY SERVICE
Leroy M. Pomraning
Over 18
As captioned above
Unknown
Dorothy R. Pomraning
Over 18
As captioned above
unknown
Defendant: Keith Pomraning
Age: Over 18
Residence: As captioned above
Employment: Unknown
Name : e I
Title: Assistant Secretary
Sworn to and subscribed Company:
before me this tei'V- day LITTON LOAN SERVICING LP
o f QQcv'-' f 2 0cn .
bli (cMILY WALKER
Notary Public, State of Texas
My Commission Expires
June 19, 2011
j
06
J
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Credit Based Asset Servicing :COURT OF COMMON PLEAS
and Securitization, LLC :CIVIL DIVISION
Plaintiff :Cumberland County
V.
;MORTGAGE FORECLOSURE
Leroy M. Pomraning :NO. 07-7436 CIVIL TERM
Dorothy R. Pomraning
Keith Pomraning
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Please issue Writ of Execution in the above matter:
Amount due
$321,760.54
Interest From 1/30/08 12,582.60
to Date of Sale 6/11/08
Ongoing Per Diem of 93.90
to actual date of sale including if sale is
held at a later date
(Costs to be added) $
CES, P. C.
Atfbiapeys'€e Plaintiff
MARK J. UDREN 'ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
/ ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
:?v
to n -6?-
?
00
F co;
CLA,
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Credit Based Asset Servicing :COURT OF COMMON PLEAS
and Securitization, LLC :CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Leroy M. Pomraning :NO. 07-7436 CIVIL TERM
Dorothy R. Pomraning
Keith Pomraning
Defendant (s)
CERTIFICATE TO THE SHERIFF
I HEREBY CERTIFY THAT:
I. The judgment entered in the above matter is based on an
Action:
A. In Assumpsit (Contract)
B. In Trespass (Accident)
x C. In Mortgage Foreclosure
D. On a Note accompanying a purchase money mortgage
and the property being exposed to sale is the
mortgaged property.
II. The Defendant(s) own the property being exposed to sale as:
A. An individual
B. Tenants by Entireties
x C. Joint Tenants with right of survivorship
D. A partnership
E. Tenants in Common
F. A corporation
III. The Defendant(s) is (are):
x A. Resident in the Commonwealth of Pennsylvania
B. Not resident in the Commonwealth of Pennsylvania
C. If more than one Defendant and either A or B above
is not applicable, state which Defendant is
resident of the Commonwea of Pennsylvania.
Resident:
UD EN LAW OFFICES, P.C.
B
Att1? 6-X-e-f` Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
,/ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
} ^a .j
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- `l".
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1 "?... i.
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Credit Based Asset Servicing €COURT OF COMMON PLEAS
and Securitization, LLC =CIVIL DIVISION
Plaintiff =Cumberland County
V.
:MORTGAGE FORECLOSURE
Leroy M. Pomraning
Dorothy R. Pomraning €:NO. 07-7436 CIVIL TERM
Keith Pomraning
Defendant(s)
C E R T I F I C A T E
Mark J. Udren, Esquire, hereby states that he is the
attorney for the Plaintiff in the above-captioned matter and that
the premises are not subject to the provisions of Act 91 because
it is:
( ) An FHA insured mortgage
( ) Non-owner occupied
( ) Vacant
( x ) Act 91 procedures have been fulfilled.
( ) Over 24 months delinquent.
This certification is made subject to the penalties of 18
Pa. C.S. Sec. 4904 relating to unsworn si ication to
authorities.
OFFICES, P.C.
Att-15 v f or_Plaint i f f
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
•LORRAINE DOYLE, ESQUIRE
/ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
s ..?,
:?
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MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Credit Based Asset Servicing ::COURT OF COMMON PLEAS
and Securitization, LLC :CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Leroy M. Pomraning :NO. 07-7436 CIVIL TERM
Dorothy R. Pomraning
Keith Pomraning
Defendant(s)
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
AFFIDAVIT PURSUANT TO RULE 3129.1
Credit Based Asset Servicing and Securitization, LLC, Plaintiff
in the above action, by its attorney, Mark J. Udr,en, ESQ., sets
forth as of the date the Praecipe for the Writ of Execution was
filed the following information concerning the real property
located at: 298 McAllister Church Road, Carlisle, PA 17013
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Leroy M. Pomraning
Dorothy R. Pomraning
Keith Pomraning
298 McAllister Church Road
Carlisle, PA 17013
298 McAllister Church Road
Carlisle, PA 17013
298 McAllister Church Road
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name Address
none
v
C
4. Name and address of the last recorded holder of every mortgage
of record:
Name Address
Credit Based Asset Servicing 4828 Loop Central Drive
and Securitization, LLC Houston, TX 77081-2226
AG Choice Farm Credit ACA 3301 West Market Street
York, PA 17404
5. Name and address of every other person who has any record lien
on the property:
Name Address
none
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
Name Address
Real Estate Tax Department
1 Courthouse Square
Carlisle, PA 17013
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
13 North Hanover Street
Carlisle, PA 17013
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale:
Name Address
Tenants/Occupants 298 McAllister Church Road
Carlisle, PA 17013
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and
belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. sec. 4904 relating to
unsworn falsification to authorities.
DATED: January 29, 2008
FILES, P. C.
A rneys(Sqx Plaintiff
MARK J. 'N-,-- ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
/ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
-
- -;
_ ??
.... -
?_ .-_
f
4
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200 -
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings®udren.com
Credit Based Asset Servicing :COURT OF COMMON PLEAS
and Securitization, LLC 'CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Leroy M. Pomraning, :NO. 07-7436 CIVIL TERM
Dorothy R. Pomraning
Keith Pomraning
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Leroy M. Pomraning
298 McAllister Church Road
Carlisle, PA 17013
Your house (real estate) at 298 McAllister Church Road, Carlisle,
PA 17013 is scheduled to be sold at the Sheriff's Sale on June
11, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA, to enforce the court judgment of
$321,760.54, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
f
M
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. You may find out the price bid by calling 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
I
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Credit Based Asset Servicing -COURT OF COMMON PLEAS
and Securitization, LLC 'CIVIL DIVISION
Plaintiff :-,Cumberland County
V.
=MORTGAGE FORECLOSURE
Leroy M. Pomraning NO. 07-7436 CIVIL TERM
Dorothy R. Pomraning
Keith Pomraning
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Dorothy R. Pomraning
298 McAllister Church Road
Carlisle, PA 17013
Your house (real estate) at 298 McAllister Church Road, Carlisle,
PA 17013 is scheduled to be sold at the Sheriff's Sale on June
11, 2008, at 10:00 am in,the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA, to enforce the court judgment of
$321,760.54, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. You may find out the price bid by calling 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Credit Based Asset Servicing =COURT OF COMMON PLEAS
and Securitization, LLC :CIVIL DIVISION
Plaintiff =Cumberland County
V.
:MORTGAGE FORECLOSURE
Leroy M. Pomraning :NO. 07-7436 CIVIL TERM
Dorothy R. Pomraning
Keith Pomraning
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Keith Pomraning
298 McAllister Church Road
Carlisle, PA 17013
Your house (real estate) at 298 McAllister Church Road, Carlisle,
PA 17013 is scheduled to be sold at the Sheriff's Sale on June
11, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA, to enforce the court judgment of
$321,760.54, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
i
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE 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 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
ATTORNEY FOR PLAINTIFF
Credit Based Asset Servicing ]COURT OF COMMON PLEAS
and Securitization, LLC 'CIVIL DIVISION
Plaintiff '-Cumberland County
V.
Leroy M. Pomraning
Dorothy R. Pomraning ::NO. 07-7436 CIVIL TERM
Keith Pomraning
Defendant(s)
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Leroy M. Pomraning
Dorothy R. Pomraning
Keith Pomraning
PROPERTY: 298 McAllister Church Road
Carlisle, PA 17013
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumberland County Sheriff's Sale on June 11, 2008, at 10:00 am, at
the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA.
Our records indicate that you may hold a mortgage or judgment on
the property which will be extinguished by the sale. You may wish
to attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date
specified by the Sheriff not later that 30 days after sale.
Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the
schedule.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7436 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CREDIT BASED ASSET SERVICING AND
SECURITIZATION, LLC, Plaintiff (s)
From LEROY M. POMRANING, DOROTHY R. POMRANING AND KEITH POMRANING
(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 $321,760.54
L.L.$ 0.50
Interest from 1/30/08 to Date of Sale 6/11/08 Ongoiing Per Diem of $93.90 to actual date of sale
including if sale is held at a later date -- $12,582.60
Atty's Comm % Due Prothy $2.00
Atty Paid $179.00
Plaintiff Paid
Date: 1/29/08
(Seal)
REQUESTING PARTY:
Name
Other Costs
Prothonotary
By:
Deputy
Address: ALAN M. MINATO, ESQUIRE
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 75860
4, N
Credit Based Asset Servicing and Securitization In the Court of Common Pleas of
LLC Cumberland County, Pennsylvania
VS Writ No. 2007-7436 Civil Term
Leroy Pomraning, Dorothy Pomraning and
Keith Pomraning
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per letter of request from Attorney Alan Minato.
Sheriffs Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Levy
Surcharge
Share of bills
So Answers:
R. Thomas Kline, Sheriff
BY Jo d-Q S
SnI A-
Real Estat Sergeant
30.00
5,453.90
15.00
.50
2.00
4.80
15.00
40.00
14.73
5,575.93
8??r?o8
$.2. SO ?,t
`553C)
1?? a13y89
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID # 45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE '- ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Credit Based Asset Servicing :COURT OF COMMON PLEAS
and Securitization, LLC ';CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Leroy M. Pomraning NO. 07-7436 CIVIL TERM
Dorothy R. Pomraning
Keith Pomraning
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Credit Based Asset Servicing and Securitization, LLC, Plaintiff
in the above action, by its attorney, Mark J. Udren, ESQ., sets
forth as of the date the Praecipe for the Writ of Execution was
filed the following information concerning the real property
located at: 298 McAllister Church Road, Carlisle, PA 17013
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Leroy M. Pomraning
298 McAllister Church Road
Carlisle, PA 17013
Dorothy R. Pomraning
Keith Pomraning
298 McAllister Church Road
Carlisle, PA 17013
298 McAllister Church Road
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name Address
none
4. Name and address of the last recorded holder of every mortgage
of record:
Name Address
Credit Based Asset Servicing 4828 Loop Central Drive
and Securitization, LLC Houston, TX 77081-2226
AG Choice Farm Credit ACA 3301 West Market Street
York, PA 17404
5. Name and address of every other person who has any record lien
on the property:
Name Address
none
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
Name Address
Real Estate Tax Department
1 Courthouse Square
Carlisle, PA 17013
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
13 North Hanover Street
Carlisle, PA 17013
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale:
Name Address
Tenants/Occupants 298 McAllister Church Road
Carlisle, PA 17013
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and
belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. sec. 4904 relating to
unsworn falsification to authorities. ------
DATED: January 29, 2008 UI}REN LAW OFFICES, P.C.
At'G _rneys`? Plaintiff
MARK J. UMMUTT- ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
,ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
UDREN LAW OFFICES, P.C. ATTORNEY
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
FOR PLAINTIFF
Credit Based Asset Servicing €COURT OF COMMON PLEAS
and Securitization, LLC. :CIVIL DIVISION
Plaintiff ;Cumberland County
V.
MORTGAGE FORECLOSURE
Leroy M. Pomraning,
Dorothy R. Pomraning
Keith Pomraning
Defendant(s)
NO. 07-7436 CIVIL TERM
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Leroy M. Pomraning
298 McAllister Church Road
Carlisle, PA.17013
Your house (real estate) at 298 McAllister Church Road, Carlisle,
PA 17013 is scheduled to be-sold at the Sheriff's Sale on June
11, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA, to enforce the court judgment. of
$321,760.54, obtained by.Plairitiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OMMR'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder.. You may find out the price bid by calling 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669=5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the. property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights. and defenses, or ways of getting
your home back, if you act immediately after the sale-.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKENA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
.com
Credit Based Asset Servicing
and Securitization, LLC
Plaintiff
V.
Leroy.M. Pomraning
Dorothy R. Pomraning
Keith Pomraning
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 07-7436 CIVIL TERM
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Dorothy R. Pomraning
298 McAllister Church Road
Carlisle, PA 17.013
Your house (real estate) at 298 McAllister Church Road, Carlisle,
PA 17013 is scheduled to be sold at the Sheriff's Sale on June
11, 2008, at 10:00 am in.the Commissioners Hearing Room, 2"a
Floor, Courthouse, Carlisle, PA, to enforce the court judgment of
$321,760.54, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
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 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID-#45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadingsoudren.com
Credit Based Asset Servicing :COURT OF COMMON PLEAS
and Securitization, LLC :CIVIL DIVISION
Plaintiff :Cumberland County
V.
MORTGAGE FORECLOSURE
Leroy M. Pomraning
Dorothy R. Pomraning
Keith Pomraning
Defendant(s)
NO. 07-7436 CIVIL TERM
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Keith Pomraning
298 McAllister Church Road
Carlisle, PA 17013
Your house (real estate) at 298 McAllister Church Road, Carlisle,
PA 17013 is scheduled to be sold at the Sheriff's Sale on June
11, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA, to enforce the court judgment of
$321,760.54, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU NAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE 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 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by"the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
. 7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LhWYER AT ONCE. IF YOU DO'NOT HAVE A
L&NYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
ALL `THAT CERTAIN TRACT OF LAND SITUATE IN WEST PENNSBORO TOWNSHIP, CUMBERLAND
COUNTY,PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT A POINT AT THE INTERSECTION OF THE CENTER LINE OF L.R 21091 AND TOWNSHIP
ROAD 482 ALSO KNOWN AS GOOD HOPE ROAD; THENCE ALONG THE CENTER LINE OF GOOD HOPE ROAD
SOUTH FIVE DEGREES NINE MINUTES WEST THREE HUNDRED TWENTY TWO AND EIGHT NINE HUNDREDTHS
FEET TO A NAIL SET IN THE CENTER LINE OF GOOD HOPE ROAD; THENCE LEAVING THE CENTER LINE
OF GOOD HOPE ROAD NORTH EIGHTY FIVE DEGREES TWENTY FOUR MINUTES WEST THREE HUNDRED SIXTY
NINE AND TWENTY NINE HUNDREDTHS FEET TO A POINT AT OTHER LAND SNOW OR FORMERLY OF CHARLES
J RIFE, OF WHICH THIS WAS ONCE A PART; THENCE-ALONG SAME NORTH ZERO DEGREES TWENTY THREE
MINUTES WEST TWO HUNDRED EIGHTY 'NINE AND THIRTY HUNDREDTHS FEET TO A NAIL SET AT THE
CENTER LINE OF L.R. 21091 AFORESAID; THENCE ALONG SAME.NORTH.EIGHTY NINE DEGREES THIRTY
SIX MINUTES FIFTY SEVEN SECONDS EAST THREE HUNDRED NINETY NINE AND THREE HUNDREDTHS FEET
TO THE POINT AND PLACE OF BEGINNING.
BEING KNOWN AS: 298 MCALLISTER CHURCH ROAD, CARLISLE, PA 17013
PROPERTY ID NO.: 46-07-0475-039A
TITLE TO SAID PREMISES IS VESTED IN LEROY M. POMRANING AND DOROTHY
R. POMRANING, HUSBAND AND WIFE, AND KEITH POMRANING, A SINGLE MAN
BY DEED FROM LEROY M. POMRANING AND DOROTHY R. POMRANING, HUSBAND
AND WIFE DATED 7/12/06 RECORDED 7/24/06 IN DEED BOOK 275 PAGE 3988.
M?
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7436 Civil
CIVIL ACTION - LAW .
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CREDIT BASED ASSET SERVICING AND
SECURITIZATION, LLC, Plaintiff (s)
From LEROY M. POMRANING, DOROTHY R. POMRANING AND KEITH POMRANING
(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 $321,760.54 L.L.$ 0.50
Interest from 1/30/08 to Date of Sale 6/11/08 Ongoiing Per Diem of $93.90 to actual date of sale
including if sale is held at a later date -- $12,582.60
Atty's Comm %
Atty Paid $179.00
Plaintiff Paid
Date: 1/29/08
(Seal)
Due Prothy $2.00
Other Costs
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name
Address: ALAN M. MINATO, ESQUIRE
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme-Court ID No. 75860
Real Estate Sale # 35
On February 25, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
West Pennsboro Township, Cumberland County, PA
Known and numbered as 298 McAllister Church Road, Carlisle,
more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: February 25, 2008
By.
t
Real Esta Sergeant
d 9- 83
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