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
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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