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PHELAN HALLINAN & SCHMIEG, LLP
John Michael Kolesnik, Esq., Id. No.308877
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
CTTIMORTGAGE INC SB/M ABN AMRO
MORTGAGE GROUP INC.
1000 TECHNOLOGY DRIVE
O'FALLON, MO 63368
Plaintiff
V.
TODD L. TRAVITZ
KARI R. TRAVITZ
8 JENNY DRIVE
BOILING SPRINGS, PA 17007-9533
Defendants
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
bw
No. 10 - 36'? ? CUMBERLAND COUNTY
CIVIL ACTION - LAW
COMPLAINT W MORTGAGE FORECLOSURE
File #: 298080
a?50
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so, the case may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATIQN ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
File #: 298080
1. Plaintiff is
CITIMORTGAGE INC SB/M ABN AMRO MORTGAGE GROUP INC.
1000 TECHNOLOGY DRIVE
O'FALLON, MO 63368
2. The name(s) and last known address(es) of the Defendant(s) are:
TODD L. TRAVITZ
KARI R. TRAVITZ
8 JENNY DRIVE
BOILING SPRINGS, PA 17007-9533
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 08/13/2003 TODD L. TRAVITZ and KARI R. TRAVITZ made, executed and
delivered a mortgage upon the premises hereinafter described to PLAINTIFF which
mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County,
in Book 1830, Page 1667.The mortgage and assignment(s), if any, are matters of public
record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g);
which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if
those documents are of public record.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 01/01/2012 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of Mortgagor to make such payments after a date specified
by written notice sent to Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith.
File #: 298080
6. The following amounts are due on the mortgage as of 05/06/2012:
Principal Balance $120,328.85
Interest $2,524.56
12/01/2011 through 05/06/2012
Late Charges $188.81
Property Inspections $67.50
Subtotal $123,109.72
Escrow Credit 507.63
TOTAL $122,602.09
7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
8. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as
required by the mortgage document, as applicable, have been sent to the Defendant(s) on
the date(s) set forth thereon.
File #: 298080
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$122,602.09, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
PHELAN HALLINAN & SCHMIEG, LLP
By: C?
Michael Kolesnik, Esquire
ney for Plaintiff
File #: 298080
LEGAL DESCRIPTION
ALL that certain tract of land situated in South Middleton Township, Cumberland County,
Pennsylvania, more fully described as follows:
BEGINNING at a point in the western dedicated right of way line of Jenny Drive at the dividing
line between Lots 34 and 35 on the hereinabove mentioned subdivision plan; thence along said
dividing line South 62 degrees 00 minutes 37 seconds West 359.24 feet to a point; thence along
the lands now or formerly of Paul M. Weaver North 37 degrees 56 minutes 34 seconds West
212.85 feet to a point; thence along the dividing line between Lots 30, 33 and 34 on said plan
North 70 degrees 24 minutes 09 seconds East 411.41 feet to a point on the western dedicated
right of way line of Jenny Drive; thence along said right of way line of a curve to the left with a
radius of 1025 feet an arc distance of 150.13 feet to a point, the Place of BEGINNING.
PROPERTY ADDRESS: 8 JENNY DRIVE, BOILING SPRINGS, PA 17007-9533
PARCEL # 40-12-0344-099
File #: 298080
VERIFICATION
Dan Fitzgerald , hereby states that he/she is employed as a Document
Control Officer of CITIMORTGAGE, INC., the Plaintiff in this matter, and is authorized to
make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage
Foreclosure are true and correct to the best of my information and belief.
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904
relating to unsworn falsification to authorities.
DATE: Name: Dan Fitzgerald
r
Title: ppCuWwM Conbd oftw
File#: 298080
Name: TRAVITZ
Attorney File No.: 298080
CITIMORTGAGE INC SB/M ABN AMRO MORTGAGE
GROUP INC.
Plaintiff(s)
VS.
TODD L. TRAVITZ
KARI R. TRAVITZ
Defendant(s)
C-)
7? C) u`
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have an attorney, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at
(717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at not
charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative
within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all
the requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal
representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the
service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in attempt to work out a reasonable arrangements with your lender
before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a
conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal
representative. However, you must provide your lawyer with all the requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format
attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be
filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an
attempt to work our reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward,
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
Date
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSTLVANIA
of Counsel for Plaintiff
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Please Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances
to determine possible options while working with your Please provide the
following information to the best of your knowledge:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different)
City:
Phone Numbers:
Email:
# of people in household:
How long?
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household:
First Mortgage Lender:
Loan:
Loan Number:
Second Mortgage Lender:
of Loan:
Loan Number:
State: Zip:
Yes ? No El Listing date: Price: $_
Realtor Phone:_
Yes ? No ?
Home:
Cell:
State: Zip:
Office:
Other:
How long?
Date you Closed Your Loan:
Type of
Type
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ? No ?
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model:
Amount owed: Value:
Automobile #2: Model:
Amount owed: Value:
Other transportation automobiles, boats, motorcycles): Model:
Year: Amount owed: Value
Year:
Year:
Monthly Income
Name of Employers:
I.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2" Mortgage Utilities
Car Payment(s) Condo/Nei . Fees
Auto Insurance Med. (not covered)
Auto fuel/repairs Other prop. payment
Install. Loan Payment Cable TV
Child Su rt/Alim. Spending Money
Da /Child Care/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ? No ?
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ? No ?
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to
resolve your delinquency?
Yes ? No ?
If yes, please indicate the status of those negotiations:
Please provide the following information, if you know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
I/We, , authorize the above named
to use/refer this information to my lender/servicer for the sole purpose of
evaluating my financial situation for possible mortgage options. I/We understand that I/we
am/are under no obligation to use the services provided by the above named
Borrower Signature
Date
Co-Borrower Signature Date
Please forward this page along with the following information to lender:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
6. Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
--HE FR()THU
?t2 JUL 23 AM 8: 38
_
C.UMBERLAHO i OWW'
PENNSYLVANIA
ONOV pt uinbt t'144
MIFF
Citimortgage, Inc Case Number
vs. 2012-3676
Todd L. Travitz (et al.)
SHERIFF'S RETURN OF SERVICE
07/16/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on July 16, 2012 at 11 15
hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the
within named defendant, to wit: Kari R. Travitz. After several attempts the Complaint in Mortgage
Foreclosure has expired.
07/16/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on July 16, 2012 at 11 5
hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the
within named defendant, to wit: Todd L. Travitz. After several attempts the Complaint in Mortgage
Foreclosure has expired.
SHERIFF COST: $68.00
July 17, 2012
SO ANSWERS,
6 _ "
R ANDERSON, SHERIFF
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~ li 9k
PHELAN HALLINAN &SCHMIEG, LLP ` "~~ ° ~ ~~.i i (~~ai~~t~ ~~~~~
Jonathan Lobb, Esq., Id. No.312174 %.n
1617 JFK Boulevard, Suite 1400 ~ E'1 ~ ~ ~'! ~ ~ ~ ~Q:
One Penn Center Plaza ~ ~E"~iy._.€~~..w1~ll~ ~~U~~~~y
Philadelphia, PA 19103 ;~--~,i
215-563-7000 ` ~'c=~SYLVA~IA
CITIMORTGAGE INC SB/M ABN AMRO COURT OF COMMON PLEAS
MORTGAGE GROUP INC.
Plaintiff CIVIL DIVISION
vs.
TODD L. TRAVITZ
KART R. TRAVITZ
Defendants
CUMBERLAND COUNTY
No. 12-3676-CIVIL
PRAECIP'E TO REINSTATE CIVIL ACTION/MORTGAGE FORECLfl~URE
TO THE PROTHONOTARY:
Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above
captioned matter.
Date: November 9, 2012
JNL/jqd, Svc Dept.
File# 298080
PHELAN HALLINAN &SCHMIEG, LLP
By:
athan Lobb, Esq., Id. No.312174
Attorney for Plaintiff
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PHELAN HAI,LINAN, LLP
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Allison F. Wells, Esq., Id. No. 309519 ! , .. ~' ~ 1
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza _ , ~ ~ ; , ~ ' "i"
~'. ,
Philadelphia, PA 19103 ~° ~_`~` `
215-563-7000
CITIMORTGAGE INC SB/M ABN AMRO COURT OF COMMON PLEAS
MORI~GAGE GROUP INC.
Plaintiff CIVIL DIVISION
vs. CUMBERLAND COUNTY
TODD L. TRAVITZ
KARI R. TRAVITZ
Defendants
No. 12-3676-CIVIL
PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above
captioned matter. ~
PHELAN
By:-~
Date: November 27, 2012
/ezk, Svc Dept.
File# 298080
Allis ells~sq 'I~d. ~Lo. 3 09519
Attorney for a tiff
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PHELAN HALLINAN, LLP
Joseph P. Schalk, Esq., Id. No. 91656
126 Locust Street
Harrisburg, PA 17101
215-563-7000 Attorney for Plaintiff
CITIMORTGAGE INC SB/M ABN AMRO
MORTGAGE GROUP INC. Court of Common Pleas
1000 TECHNOLOGY DRIVE
O'FALLON,MO 63368 Civil Division
Plaintiff Term
Vs No.2012-3676-CIVIL
TODD L.TRAVITZ
KARI R.TRAVITZ Cumberland County
8 JENNY DRIVE
BOILING SPRINGS,PA 17007-9533
Defendants
MOTION TO LIFT CONCILIATION STAY
Plaintiff, Bank of America, Successor (hereinafter "Plaintiff'), by its attorney, Joseph P.
Schalk, Esquire, hereby files the within Motion to Lift Conciliation Stay and in support thereof
avers as follows:
1. On June 12, 2012, Plaintiff filed a Complaint in Mortgage Foreclosure against
Defendants for their failure to make monthly payments of principal and interest upon their
mortgage due January 1, 2012 and each month thereafter. A true and correct copy of the
Complaint is attached hereto, made part hereof and marked as Exhibit A.
2. On December 16, 2012, Plaintiff completed service of the Complaint in Mortgage
Foreclosure along with service of the Cumberland County Residential Mortgage Foreclosure
Diversion Program Notice for the Defendants. A true and correct copy of the Affidavit of
Service is attached hereto, made part hereof and marked as Exhibit B.
298080
3. Pursuant to the Cumberland County Administrative Order February 28, 2012,
which created the Cumberland County Residential Mortgage Foreclosure Diversion Program,the
Foreclosure action is stayed for sixty(60)days from the date of service.
4. Within 60 days after service of the complaint,the Defendant may opt into the
program by filing a Request for Conciliation Conference with the Court. Upon the filing of the
request,the Court will schedule a Conciliation Conference. The program provides that
Defendant must contact MidPenn Legal Services within the first twenty(20)days of receipt of
notice if not represented by counsel.
5. If more than sixty(60)days has elapsed since the service of Notice of Residential
Mortgage Foreclosure Diversion Program and the Defendant has not opted to participate in the
Diversion Program Plaintiff may petition the Court to lift the stay and remove the case from the
Diversion Program.
6. Defendant failed to opt into the Cumberland County Residential Mortgage
Foreclosure Diversion Program within sixty(60)days of service.
7. Since Defendant has opted not to participate in the Diversion Program, it is
appropriate for the stay to be lifted.
WHEREFORE, Plaintiff respectfully requests that this matter be removed from the
Cumberland County Residential Mortgage Foreclosure Diversion Program and the automatic
stay be lifted.
Respectfully submitted,
PHELAN HALLINAN, LLP
Date: P, BY:
Schalk, Esquire
#P me for Plaintiff
298080
Exhibit A
298080
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PHKAN HAUJNAN&SCHm EG,LLP
Iota bfidmid Kolwil ,Esq„Id.No.308877
1617 IPK Bwkvwd,Suite 1400 ATTORNEY F OR PLAIIVTIFF
One POW Center F1az$
Filadnlphis,PA 19103
215-563-7000
CPTIMORTGAGE INC S/B/M ABN AMMO
MORTGAGE GROUP INC. COURT OF COMMON PLEAS
1000 TECEMLOGY DRIVE
OTALLON,MO 63368 CIVIL DIVISION
Plaintiff TERM
v. NO. G o
TODD L.TRAVnZ
KAKI R.TRAVnZ CUMBERLAND COUNTY
8 JENNY DRIVE
BOILING SPRINGS,PA 17007-9533
Defendants
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Fite#: 2"M
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty(20)days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so,the case may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATIQN ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE,PA 17013
(717)249-3166
(800)990-9108
File#: 298080
1. Plaintiff is
CITIMORTGAGE INC SB/M ABN AMRO MORTGAGE GROUP INC.
1000 TECHNOLOGY DRIVE
O-FALLON, MO 63368
2. The name(s) and last known address(es) of the Defendant(s) are:
TODD L.TRAVITZ
KA.RI R.TRAVITZ
8 JENNY DRIVE
BOILING SPRINGS,PA 17007-9533
who is/are the mortgagor(s) and/or real owner(s)of the property hereinafter described.
3. On 08/13/2003 TODD L. TRAVITZ and KARI R. TRAVITZ made, executed and
delivered a mortgage upon the premises hereinafter described to PLAINTIFF which
mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County,
in Book 1830, Page 1667.The mortgage and assignment(s), if any, are matters of public
record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(8);
which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if
those documents are of public record.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 01/01/2012 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of Mortgagor to make such payments after a date specified
by written notice sent to Mortgagor,the entire principal balance and all interest due
thereon are collectible forthwith.
File#: 298080
6. The following amounts are due on the mortgage as of 05/06/2012:
Principal Balance $120,328.85
Interest $2,524.56
12/01/2011 through 05106/2012
Late Charges $188.81
Property Inspections $67.50
Subtotal $123,109.72
Escrow Credit 507. 3
TOTAL $122,602.09
7. Plaintiff is not seeking a judgment of personal liability(or an in personam judgment)
against the Defendant(s) in the Action;however,Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s)has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy,but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
8. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as
required by the mortgage document, as applicable,have been sent to the Defendant(s)on
the date(s) set forth thereon.
Fie#- 298080
WHEREFORE,Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$122,602.09,together with interest,costs,fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs,and for the foreclosure and sale of the
mortgaged property.
PHELAN HALLINAN&SCHMIEG,LLP
By:
Michael Kolesnik, Esquire
ttorney for Plaintiff
File : 298080
LEGAL DESCRIPTION
ALL that certain tract of land situated in South Middleton Township,Cumberland County,
Pennsylvania, more fully described as follows:
BEGINNING at a point in the western dedicated right of way line of Jenny Drive at the dividing
line between Lots 34 and 35 on the hereinabove mentioned subdivision plan;thence along said
dividing line South 62 degrees 00 minutes 37 seconds West 359.24 feet to a point; thence along
the lands now or formerly of Paul M. Weaver North 37 degrees 56 minutes 34 seconds West
212.85 feet to a point; thence along the dividing line between Lots 30, 33 and 34 on said plan
North 70 degrees 24 minutes 09 seconds East 411.41 feet to a point on the western dedicated
right of way line of Jenny Drive; thence along said right of way line of a curve to the left with a
radius of 1025 feet an arc distance of 150.13 feet to a point, the Place of BEGINNING.
PROPERTY ADDRESS: 8 JENNY DRIVE,BOILING SPRINGS,PA 17007.9533
PARCEL#40-12-0344-099
File#: 298080
VERIFICATION
Dan Fitzgerald_ hereby states that he/she is employed as a Document
Control Officer of CITIMORTGAGE, INC., the Plaintiff in this matter, and is authorized to
make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage
Foreclosure are true and correct to the best of my information and belief.
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904
relating to unworn falsification to authorities.
r — r
DATE: 2-- Name: Dan Fitzgerald
. v /
Title: Etcumer><Corgi offift
File#: 298080
Name: TRAVITZ
Attorney File No.: 298080
IN THE COURT OF COMMON PLEAS
CITIMORTGAGE WC S/BCM ABN AMRO MORTGAGE OF CUMBERLAND COUNTY,
GROUP INC. PENNSTLVANIA
Plaintiff(s)
vs.
TODD L. TRAV'ITZ
KARI R. TRAVITZ
Defendant(s) Civil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action,you may be able to
participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have an attorney,you must take the following steps to be eligible fora conciliation
conference. First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal Services at
(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative at not
charge to you.Once you have been appointed a legal representative,you must promptly meet with the legal representative
within twenty(20)days of the appointment date.During that meeting,you must provide the legal representative with all
the requested financial information so that a loan resolution proposal can be prepared on your behalf.If you and your legal
representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a
Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the
service upon you of the foreclosure complaint.If you do so and a conciliation conference is scheduled,you will have an
opportunity to meet with a representative of your lender in attempt to work out a reasonable arrangements with your lender
before the mortgage foreclosure suit proceeds forward.
If you are represented by a-lawyer,you and your lawyer must take the following steps to be eligible for a
conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal
representative.However,you must provide your lawyer with all the requested financial information so that a loan
resolution proposal can be prepared on your behalf If you and your lawyer complete a financial worksheet in the format
attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be
filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint.if you do so and a
conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an
attempt to work our reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward,
IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
Date Si of Counsel for Plaintiff
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Please Docket#
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance,your lender must consider your circumstances
to determine possible options while working with your Please provide the
following information to the best of your knowledge:
Borrower name(s):
Property Address:
City: State: Zip.
Is the property for sale? Yes 0 No Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes No
Mailing Address(if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
#of people in household: How long?
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
#of people in household: How long?
First Mortgage Lender: Type of
Loan:
Loan Number: Date you Closed Your Loan:
Second Mortgage Lender: Type
of Loan:
Loan Number:
Total Mortgage Payments Amount: $, Included Taxes& Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No❑
If yes,provide names,location of court, case number&attorney:
Assets A Value:
Horne: $ $
Other Real Estate: $ $
Retirement Funds. $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile#1: Model: Year:
Amount owed: Value:
Automobile#2: Model: Year:
Amount owed: Value:
Other gpgRgrtapon(automobiles,boats,motorcycles): Model:
Year: Amount owed: Value
MoRAtc afire
Name of Employers:
1.
2.
3.
Additional Income Description(not wages):
I, monthly,amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Month v Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 o e Utilities
Car Pa meats Condo/Neigh:Fees
Auto Insurance Meth. not covered
Auto fueU airs Other prop. ent
Install.Loan t nt Cable TV
Child.Su ort/Alim. Spend! Mon!
Da !Child Care/Tuit. Other Ex nses
Amount Available for Monthly Mortgage Payments Based on Income&Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes,please provide the following information:
Counseling Agency:
Counselor:
Phone(Office): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP)assistance?
Yes ❑ No ❑
If yes,please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to
resolve your delinquency?
Yes ❑ No ❑
If yes,please indicate the status of those negotiations
Please provide the following information, if you know,regarding your lender or lender's loan
servicing company:
Lender's Contact(Name): Phone:
Servicing Company(Name)
Contact: Phone:
I/We, , authorize the above named
to use/refer this information to my lender/servicer for the sole purpose of
evaluating my financial situation for possible mortgage options. I/We understand that Uwe
am/are under no obligation to use the services provided by the above named
Borrower Signature Date
Co-Borrower Signature bate
Please forward this page along with the following information to lender:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
6. Listing agreement(if property is currently on the market)
Exhibit B
298080
AFFIDAVIT OF SERVICE--CUMBERLAND JQD
COUNTY:CUMBERLAND
CITIMORTGAGE INC S/B/M ABN AMRO MORTGAGE
GROUP INC. COURT NO. 12-3676-CIVIL
N
TODD TYPE OF ACTION
KARI R.TRAVITZ _ U _Mortgage Foreclosure
Eviction
SERVE KARI R.TRAVITZ AT: XX Civil Action
8 JENNY DRIVE,BOILING SPRINGS,PA 17007-9533 Complaint on Promissory Note
***PLEA819 POST THE PROPERTY***
***IN ACCORDANCE WITH THE*****
***ATTAMP COUR ORDER******
Served
Posted madp.knoon XMI R.TRAVITb,Defendant on the _day of .fee t ,2 20_,,,JZ
at o1C1d0C, M..at 8 JENNY DRIVE,BOILING SPRINGS,PA 17007-9333,in the manner described below;
ttttt .
Adult ilr membei with whom Defendant(s)reside(s).
t `g�sldimtteb tq gtiv�ctte�tglil#p:
Description: Age Height Weight Race— Sex Other
I competent adult,being duly sworn according to law,depose and state that I personally posted a true and correct
copy of the ComsrlaMt In Martgage Foreclosure issued in the captioned case on the date and the address indicated above,i understand that this
statement is made subject to the penalties of 18 Pa.C.S.Sec.4904 relating to unsworn falsiftm6on to authorities.
DATE: C2" �Z NAME,
PRINTED NAME:Ci
TITLE: T
NOT S ,ERVFp.
On the, day of 20_,at_o'clock_.M.,Defendant NOT FOUND because:
Vacant Does Not Exist —Moved Does Not Rcsidc(Not Vacant)
_No Answer on att _w_
Service Refused
Other:
PHS298080
PHELAN HALLINAN, LLP
Joseph P. Schalk, Esq., Id. No. 91656
126 Locust Street
Harrisburg, PA 17101
215-563-7000 Attorney for Plaintiff
CITIMORTGAGE INC SB/M ABN AMRO Court of Common Pleas
MORTGAGE GROUP INC.
1000 TECHNOLOGY DRIVE Civil Division
O'FALLON,MO 63368
Term
Plaintiff
No.2012-3676-CIVIL
Vs
Cumberland County
TODD L.TRAVITZ
KARI R.TRAVITZ
8 JENNY DRIVE
BOILING SPRINGS,PA 17007-9533
Defendants
CERTIFICATION OF SERVICE
I certify that a true and correct copy of Plaintiff's Motion to Lift Conciliation Stay and
proposed Order were sent via first class mail to the person listed below on the date indicated:
TODD L.TRAVITZ
KARI R.TRAVITZ
8 JENNY DRIVE
BOILING SPRINGS,PA 17007-9533
Date: o 73 By:
rm ph S chalk, Esquire
A y for Plaintiff
298080
IN THE COURT OF COMMON PLEAS CUMBERLAND COt*.Y,PENNSYLVANIA
CITIMORTGAGE INC SB/M ABN AMRO
MORTGAGE GROUP INC. Court of Common Pleas
1000 TECHNOLOGY DRIVE
O'FALLON,MO 63368 Civil Division
Plaintiff Term
Vs No.2012-3676-CIVIL
TODD L.TRAVITZ Cumberland County
KARI R.TRAVITZ
8 JENNY DRIVE
BOILING SPRINGS,PA 17007-9533
Defendants
ORDER �.
AND NOW,this +Z 1 day of m4w-CA ��013, upon consideration of
Plaintiff's Motion to Lift Conciliation Stay in the above captioned matter, it is hereby
ORDERED and DECREED that this matter is removed from the Cumberland County
i
Residential Mortgage Foreclosure Diversion Program; it is further
1 ORDERED and DECREED that the automatic Stay is lifted and Plaintiff may proceed
p
with its Mortgage Foreclosure Action.
BY THE COURT:
J.
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C-j rj °3^,
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✓"�,�lccK eta ll.'�Q,, � __�c-��,, `� -{ "�' :. .
298080
CC : Todd L. Travitz and Kari R. Travitz
Joseph P. Schalk, Esq., Id. No. 91656 s.
Y y4 Attorney for Plaintiff
PHELAN HALLINAN, LLP
Joseph P. Schalk, Esq., Id. No. 91656
126 Locust Street
Harrisburg, PA 17101
215-563-7000
TODD L.TRAVITZ
KARI R.TRAVITZ
8 JENNY DRIVE
BOILING SPRINGS,PA 17007-9533
i
I
298080
Phelan Hallinan,LLP 1j r- VE P R �Qttorney For Plaintiff
1617 JFK Boulevard,Suite 1400 Im WR It AH !
One Penn Center Plaza ND COUNT
Philadelphia,PA 19103 CUMBERL A
215-563-7000 PENNSYL�a1A
CITIMORTGAGE INC S/B/M ABN Court of Common Pleas
AMRO MORTGAGE GROUP INC.
Plaintiff Civil Division
vs CUMBERLAND County
TODD L.TRAVITZ No. 12-3676-CIVIL
KARI R.TRAVITZ .
Defendant
PRAECIPE
TO THE PROTHONOTARY:
❑ Please withdraw the complaint and mark the action Discontinued and Ended without prejudice.
❑ Please mark the above referenced case Settled, Discontinued and Ended.
❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended.
® Please Vacate the Judgment entered.
Date: LA I Ida PHEL P
sy
Al F.Aqckennan, Esq., Id. No.309519
far Plaintiff
PHS#298080
OX+
Phelan Hallinan,LLP Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
CITIMORTGAGE INC S/B/M ABN AMR0 Court of Common Pleas
MORTGAGE GROUP INC.
Plaintiff Civil Division
V. CUMBERLAND County
TODD L. TRAVITZ No. 12-3676-CIVIL
KARI R. TRAVITZ
Defendant PHS#298080
CERTIFICATION OF SERVICE
I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by
regular mail to the person(s) on the date listed below:
TODD L. TRAVITZ
KARI R. TRAVITZ
8 JENNY DRIVE
BOILING SPRINGS,PA 17007-9533
Date: 9 lid PHELAN HALLINLLP
BY: j
Al an d.No.3 09519
Attorney or
or Plaintiff