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HomeMy WebLinkAbout09-4516 GOLDBECK McCAFFERTY & MCKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM M&T BANK SB/M MANUFACTURERS & TRADERS TRUST COMPANY 1100 Wehrle Drive 2nd Floor Williamsville, NY 14221 TODD L. TRAVITZ KARI R. TRAVITZ vs. Plaintiff Mortgagors and Record Owners 8 Jenny Drive Boiling Spring, PA 17007 Defendants Term No. oq - 451(, (2mi_lem CIVIL ACTION: moRTGAGr NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 claim in the Complaint of 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.j2hfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.Dhiladelphiafed.orp-/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention&goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 82325FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is M&T BANK S/B/M MANUFACTURERS & TRADERS TRUST COMPANY, 1100 Wehrle Drive, 2nd Floor Williamsville, NY 14221. 2. The names and addresses of the Defendants are TODD L. TRAVITZ, 8 Jenny Drive, Boiling Spring, PA 17007 and KARI R. TRAVITZ, 8 Jenny Drive, Boiling Spring, PA 17007, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On December 20, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MANUFACTURERS & TRADERS TRUST COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1978 Page 1741.. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for December 04, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$55,141.51 Interest from 12/04/2008 through 01/03/2009 at 5.6300% ............................... ....$263.50 Interest from 01/04/2009 through 02/03/2009 at 6.0200% .....................................$281.79 Interest from 02/04/2009 through 03/03/2009 at 5.2100% .....................................$220.36 Interest from 03/04/2009 through 04/03/2009 at 5.7750% .....................................$270.32 Interest from 04/04/2009 through 05/31/2009 at 5.5800% ............... ......... $340.38 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$2,757.08 Late Charges from 12/04/2008 to 05/31/2009 ............................................. $105.12 Costs of suit and Title Search ......................................................................$900.00 Fees ................................................................................................................$28.50 $60,308.56 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $60,308.56, together with interest at the rate of $8.57, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: ` p-c ? (?N (-'1C kac? GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I,-- C Zees , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. Date: (? a to a?A9 c Christopher M. Zeiw Vice President #82325FC - TODD L. TRAVITZ and KARL R. TRAVITZ 8 Jenny Drive Boiling Spring, PA 17007 Ey, hibit A UL Im? CIRTAIN tract of land aituatod in South lsiddletan C"bar County, d mituatod j llo aswf n cup d o ws , more fully 4aearibad ° m ABa u>rp at a point in the v line of Jenny Drive at tAe diVaaitarn dedicated right of vat On the hereinabove iv Una betvean Lots 3 C3 p b montionep 4 and 35 dividing line South 42 subdivision plan; thence along said root to da4reaa a point. ca,mUntea 37 seeand o p thence o Nast 354.x4 a2 Ong the lands now or fOrnarly of Paul K. WA vor North 37 degrees 5d ninntes 3d 3*-nds w feet to a paint th illilUI1111111 ; est 212.D5 ence Along Us dividing lone betw"A Lots 30, 33 and 34 on Aaid Plan North 70 degrees anat 411.41 feet t 2q TAiftutQ* g o a Point on the W0arn dadicated right- nof way line of Jenny Drive; theme along said right at way ine of a ?°a to the Wt With a Yadi D II I 0 9 2 ua of 3025 feet an are distance of 150.13 fact (errpnaouslY set forth prior a point, the place of BU deed an 59 c 13? t lkf6i . o 1f6. t at way. a,i34.7 egllata feat axoigaiVe of dedlostsd right at Map ZP 3 Blau Of urtAer described as Let #c. 34 On the aubdiviaian Plan Ph&" 2 of Plan No. 3 for Jepaph Manor, pr arcd Phan Q. Fisher, R.B., dated November 1, 1990, and recoY'ded In 01Rb*rland County Plan gook 43, page al. Gene V?aVMa the Osaw b tre=t or land that pymcna ;. 19 Diehl and v 1# le in the office or 1993 a , , and rcterdad tam ac?W.leaof D4da inn one in Dead d Book gNNy Vdlumo 35, Page 28II fnr 5,j granted ?and? ycd u M L builders, Ina, Ill m rS hltilllnll PdcE ?? low P, Ex Fi6it B ACT 91 NOTICE DATE OF NOTICE: June 1 2009 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mort a e on our home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pqges. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM EMAP ma be able to help to save vow home This Notice explains how the pro?am works. To see if HEMAP can hel ou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with ou when ou meet with the Counselin A enc . The name address and hone number of Consumer Credit Counseling A envies servin our Coun are listed at the end of this Notice. If ou have ouestions you ma can the Pennsylvania Housin Finance A enc t hearing can call 717 oll free at 1-800- 42-2397. arsons with impaired 780-1 869. This Notice contains important legal information. If you have any representatives at the Consumer Credit Counseling Agency may be able to help explainnt. You may also want to contact any attorney in your area. Th to help you e local bar association may be able find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuer viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible pars un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el coal puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEWR Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 Date: June 1, 2009 Homeowners Name: TODD L. TRAVITZ and KART R. TRAVITZ Property Address: 8 Jenny Drive, Boiling Spring, PA 17007 Loan Account No.: 44449328954998 Ongmal Lender: MANUFACTURERS & TRADERS TRUST COMPANY Current Lender/Servicer: M&T BANK HOMEOWNERS' 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 (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 33 DAYS. IF YOU DO NOT FOR EMERGENCY MnRTf a r_1W AQeTC1r. 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 tele»hone numbers of desi ated consumer credit mi nQPlin., r -1 - - .. - - 2 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.) 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. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEM" APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. 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. 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: 8 Jenny Drive, Boiling Spring, PA 17007 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 12/04/2008 thru 6/1/2009 (3 mos. at $356.02 /month) $1,068.06 (1 mos. at $ 398.28/month) $398.28 (1 mos. at $402.81/month) $402.81 (1 mos. at $401.30/month) $401.30 (1 mos. at $405.82/month) $405.82 (b) Late charges from 12/04/2008 thru 6/ 1 /2009 $105.12 (c) Other charges, Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $2,781.39 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 2 781.39 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either b cashier's check certified check or move order made a able and sent to: M&T BANK 1100 Wehrle Drive 2nd Floor Williamsville, NY 14221 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 inten s to exercise its n *P to accelerate the wor a_ze 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 wort o - pd property ILF T MOR GAGE IS FORECLOSED UPON - The mortgaged Sheriff to pay off the mortgage debt. If the lender refers your case to attorneys,lbut youdcure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorneys fees that were actually incurred, ?rt Y ed, 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 er A you wlll not be reauired 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 SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, ou still have the ri t to cure the default and prevent the ale at anv time ,- r., .,,,.. under the marta e ------ --" .."""• ulc lenaer ana onx?in an other r uirements 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 a Sheriff's Sale of the mortgaged property could be held would be approximately four (41 to six (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 cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: M&T BANK Address: 1100 Wehrle Drive 2nd Floor Williamsville, NY 14221 Phone Number: 716-630-4912 Fax Number: 716-630-4900 Contact Person: Lindsay Pohl 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 ro Sheriffs Sale, a lawsuit to remove you and your furnishings and other belong' p pd b after the the lender at any time. &4 could be started by ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding and costs are paid prior to or at the sale and that the other r ' charges and att orney's fees equirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: 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. Contact Person: Lindsay Pohl Phone Number: 716-630-4912 6 HEMAP Consumer Credit Counseling Agencies Report last updated: M&200B,?i2:4, Pit Lyoom.Ckrbr Co Comm tc Comm AcUon 2138 Lincoln Sh" P.O. Box 3588 WMwnaport, PA 17703 570.328.0587 COLUMBIA County Armorer Croft Coun - aft ii Insthft 212 BwMdNtavW n Hwy NeoooPed4 PA 18835 888.488.8847 CCCS of Moruteaatern PA 401 Latest street PRtaton. PA 18640 570.6022227 800.822.9537 CRAWFORD County Booker T. Washington center 1720 Hobrd street Erie, PA 18508 814.453.5744 CCCS 01 Western PA 4402 Pea* Street Erle, PA 16509 888511.=T ext 108 888511.2227 wd 100 Center for Family Senriaee, Inc. 213 Center Street MO"10, PA 16335 814.337.8460 Gra#er Erie Community Action Committee 18 West "street Erie, PA 18601 814A59A581 601 kKft= Avenue Fw"ll, PA 18121 724.981.5910 tit. iirtkr Center 1701 Parade Sbw Erb, PA 18509 814.452.6113 CUMBERLAND County Adeaw O hAw big gAulthwily 40 E High Street Cieityaburg, PA 17325 717.334.1618 CCCS of Weatarn PA 2000 L.kVbetown Road Hwfbburp, PA 17102 888.5112127 888.5112227 Community Action Comte of CaPUM 1514 DerryStreet HarrbWV, PA 17104 717.232.9757 Lovaehip,1n4. 2320 North 5th Street Hanteburg, PA 17110 7172322107 Wranathe 43 PhiadelPhla Avenue Wayneaboro, PA 17288 717.7622285 PHFA 211 North Front street Harrbbtrg, PA 17110 717.780.3940 800.342.2397 DAUPHIN Cou CCCS of Western PA - 2000 Ltngbetwm Road Harditrg, PA 17102 888.5112227 888.511.2227 Community Action Commiseton of Capital Region 1514 Derry Street HWflobu?g, PA 17104 717.232.9757 Laeva"IA kte, 2920 North 5th Street Harritbvg, PA 17110 717.292.2207 Opportunity Ina 301 East Medea Stroat York, PA 17403 717.424.3845 PHFA 211 North Front street Hartbbrug, PA 17110 717.780..3940 800.3422397 DELAWARE Aaam Housing Corporatbn -- 848 North Broad Street Phbdelphb, PA 19130 215.785.1221 Pape 7 Of 19 CJ FILE! li-"P(CfE OF THE P"' 2009 U -1 Phi 3' G ! J LJ x'18 so P Q AT q CIL psu i 5to o?oZ'IloBa Sheriffs Office of Cumberland County R Thomas Kline ?IL4?f } r- , Sheriff Qv Ronny R Anderson 4161,11tr of 't ?nbrr 4114 Chief Deputy 2la (v'1 L ?? Jody S Smith Civil Process Sergeant OFFICE rF FEE 5"ERIF (;;;f Edward L Schorpp Solicitor M & T Bank vs. Case Number Todd L. Travitz 2009-4516 SHERIFF'S RETURN OF SERVICE 08/01/2009 08:35 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 1, 2009 at 0835 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kari R. Travitz, by making known unto Todd L. Travitz, husband of defendant at 8 Jenny Drive Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. 08/01/2009 08:35 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 1, 2009 at 0835 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Todd L. Travitz, by making known unto himself personally, defendant at 8 Jenny Drive Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $54.80 August 03, 2009 SO ANSWERS, pe- R THOMAS KLINE, SHERIFF Deputy Sheriff m ?,,. GOLDBECK McCAFFERTY & MCKEEVER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 M&T BANK SB/M MANUFACTURERS & TRADERS TRUST COMPANY 1100 Wehrle Drive 2nd Floor Williamsville, NY 14221 Plaintiff VS. TODD L. TRAVITZ KARI R. TRAVITZ 8 Jenny Drive Boiling Spring, PA 17007 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 09-4516 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. Michael T. McKeever, Esquire Attorney for Plaintiff FlLEa-C {CE of THE PROTHONOTARY 2009 NOV -2 PM 3: 36 CUB L?.::L . i> UN1Y