Loading...
HomeMy WebLinkAbout07-0696In the Court of Common Pleas of Cumberland Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM (Mortgagor(s) and Record Owner(s)) 57 Tabor Road Newburg, PA 17240 Defendant(s) PRAECIPE FOR JUDGMENT No. 07-696 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. Enter the Judgment in favor of Plaintiff and against JOSEPH A. ROHM and ANNA M. ROHM by default for want of an Answer. Assess damages as follows: Debt Interest from 03/13/07 to Date of Sale Total (Assessment of Damages attached) $66,304.93 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPVIFI f D AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or deliv ed t the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at t ten daa or to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A. I.D. #16132 AND NOW ! !2ff r? _ /?__ p2 d6 7 ?Jtfdgment is entered in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE and against JOSEPH A. ROHM and ANNA M. ROHM by default for want of an Answer and damages assessed in the sum of $66,304.93 as per the above certification. _ n opo Prothonotary Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff No. 07-696 vs. JOSEPH A. ROHM ANNA M. ROHM (Mortgagors and Record Owner(s)) 57 Tabor Road Newburg, PA 17240 Defendant(s) 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. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Protho tary By: If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 AMQ-1646 r 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. DATE OF THIS NOTICE: March 2, 2007 TO: ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET- BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM (Mortgagor(s) and Record Owner(s)) 57 Tabor Road Newburg, PA 17240 Defendant(s) TO: ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 07-696 IMPORTANT NOTICR 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 (10) 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY A BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, JOSEPH A. ROHM, is about unknown years of age, that Defendant's last known residence is 57 Tabor Road, Newburg, PA 17240, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldier; of Congress of 1940 and its Amendments. Date: 646 r 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. DATE OF THIS NOTICE: March 2, 2007 TO: JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET- BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. JOSEPH A. ROHM ANNA M. ROHM (Mortgagor(s) and Record Owner(s)) 57 Tabor Road Newburg, PA 17240 Defendant(s) TO: JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 07-696 IMPORTANT NOTIC"F. 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 (10) 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 IQ sevh Garwlieck Ir GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, ANNA M. ROHM, is about unknown years of age, that Defendant's last known residence is 57 Tabor Road, Newburg, PA 17240, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or of rw'se within the provisions of the Soldiers' and Sailors' Ci it lief Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM (Mortgagor(s) and Record owner(s)) 57 Tabor Road Newburg, PA 17240 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 07-696 ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS- THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING A REEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, and against JOSEPH A. HM d ANNA M. ROHM for failure to file an Answer in the above action within (20) days (or sixty (60) ays if d fendant is the United States of America) from the date of service of the Complaint, in the sum of $66,3 4.93. Joseph A. Go Attorney for I hereby certify that the above names are correct and that the pre' creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS 7 MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED I UNDER THE POOLING AND SERVICING AGREEMENT DATED A WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA known address(es) of the Defendant(s) is/are JOSEPH A. ROHM, 57 Tal ANNA M. ROHM, 57 Tabor Road Newburg, PA 17240; §e residency .US ZF - THR S I 2868 and tl it Road Nel address of the judgment AMERIQUEST GH CERTIFICATES, BER 1, 2002, t the name(s) and last burg, PA 17240 and GOLDBECK] BY: Joseph A. Attorney for P ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $58,224.81 Interest from 09/01/2006 through $3,998.95 03/12/2007 Reasonable Attorney's Fee $2,911.24 Late Charges $197.05 Costs of Suit and Title Search $900.00 Corporate Advance $15.00 Escrow $57.88 AND NOW, this 12 1day of A&I&Ck 2007 damages are assessed as above. Pro Prothy Drj D 40 t' t Co "{? V PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-696 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 03/13/07 to Date of Sale at 12.9900% (Costs to be added) $66,304.93 GOLDBECK 'F & McKEEVER BY: Joseph A. oldbeckAttorney for PI tntiff 'n Z w °vc?7d?a°? ? O ° W r cl, O V'UA 4d? x o o`- ONO z?wWAx xd? a? H o0 o???W? ?? ??' ? wE a Z N H P? , O v ? 'o" + U W W H u ??U W .l 1 p, t L 1 M ?y Y y Y y tIA (:z .. y r w y ? V a? y 7 ? v od v" tj o V ct ?" cat !?C ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF HOPEWELL, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN A TOWNSHIP ROAD AT CORNER OF LANDS NOW OR FORMERLY OF RICHARD GUYER; THENCE IN A SOUTHERLY DIRECTION AND BY LANDS OF THE SAID RICHARD GUYER AND ALSO BY LANDS NOW OR FORMERLY OF GEORGE MONN, FIVE HUNDRED (500) FEET TO AN IRON PIN; THENCE IN AN EASTERLY DIRECTION BY LANDS NOW OR FORMERLY OF J. PRESTON THRUSH ONE HUNDRED FIFTY (150) FEET TO AN IRON PIN; THENCE BY THE SAME AND IN A NORTHERLY DIRECTION (500) FEET TO A POINT IN THE CENTER OF THE AFORESAID TOWNSHIP ROAD; THENCE BY THE CENTER OF THE AFORESAID TOWNSHIP ROAD IN A WESTERLY DIRECTION ONE HUNDRED FIFTY (150) FEET TO THE PLACE OF BEGINNING. CONTAINING 2 ACRES MORE OR LESS. TAX PARCEL NO: 11-06-0043-068 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-696 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET- BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff (s) From JOSEPH A. ROHM AND ANNA M. ROHM (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 $66,304.93 L.L. $30 Interest FROM 3/13/07 TO DATE OF SALE AT 12.9900% Atty's Comm % Due Prothy $1.00 Atty Paid $142.72 Other Costs Plaintiff Paid Date: MARCH 13, 2007 (Seal) ueputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 vs. JOSEPH A. ROHM ANNA M. ROHM (Mortgagor(s) and Record Owner(s)) 57 Tabor Road Newburg, PA 17240 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-696 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 57 Tabor Road Newburg, PA 17240 1.Name and address of Owner(s) or Reputed Owner(s): JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 2. Name and address of Defendant(s) in the judgment: JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PENN LAUREL GIRL SCOUT COUNCIL 1600 Mt. Zion Road P.O. Box 20159 York, PA 17402 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street PO BOX 15057 Harrisburg, PA 17101 PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street Harrisburg, PA 17101 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 57 Tabor Road Newburg, PA 17240 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and information and belief. I understand that false statements herein are m relating to unsworn falsification to authorities. DATED: March 12, 2007 BY: Jose Attorney rect to fl* best of my personal knowledge or subject the penalties of 18 Pa. C.S. Section 4904 cc F TY & McKEEVER ol ec Jr., Esq. rP?Iaintiff r-a (? L? :70 -c1 07-696 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff Vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s Term No. 07-696 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROHM, JOSEPH A. JOSEPH JL ROHM 57 Tabor Road Newburg, PA 17240 Your house at 57 Tabor Road, Newburg, PA 17240 is scheduled to be sold at Sheriff s Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $66,304.93 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07-696 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-696 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: 717-243-9400 or. 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). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). 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@p-oldbecklaw.com. Call Judy 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 AMQ-1646. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. - c 2 A r r? f"P ? ? 07-696 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff Vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s Term No. 07-696 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROHM, ANNA M. ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Your house at 57 Tabor Road, Newburg, PA 17240 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $66,304.93 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07-696 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-696 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: 717-243-9400 or. 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). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). 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 Judy 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 AMQ-1646. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. r? ??. ?°.: - ^? S -. j ..? '4'7 ...,... ?-. ?..'J .? { "?? _. -.`., i+# ?? (.. ? .... ? ?} ?. l? 07-696 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff Vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s Term No. 07-696 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROHM, JOSEPH A. JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 Your house at 57 Tabor Road, Newburg, PA 17240 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $66,304.93 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07-696 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-696 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: 717-243-9400 or. 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). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). 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@2oldbecklaw.com. Call Judy 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 AMQ-1646. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. w L "1 _ yy Tai / }y lt? ' _ -?':< i Ti GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 W W W.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE VS. JOSEPH A. ROHM ANNA M. ROHM Mortgagors and Real Owners 57 Tabor Road Newburg, PA 17240 Defendants Term No. CIVIL ACTION: MC) TGAGF- " CLOOLME 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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. 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 INFORMACIGN DE CGMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, RSTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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: 717-243- 9400 or. 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). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). 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 1-866413-2311 or via email at homeretention(@,eoldbecklaw.com. Call Judy 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 AMQ-1646. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 6 7. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868. 2. The names and addresses of the Defendants are JOSEPH A. ROHM, 57 Tabor Road, Newburg, PA 17240 and ANNA M. ROHM, 57 Tabor Road, Newburg, PA 17240, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On May 22, 2002 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1760, Page 10. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. 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 October 01, 2006 and each month thereafter and by the terms 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. The following amounts are due to Plaintiff on the Mortgage: Corporate Advance .............................................................. Escrow--- - Principal Balance ....................................................................................$58,224.81 Interest from 09/01/2006 through 02/28/2007 at 12.9900% .....................$3,750.31 Per Diem interest rate at $20.72 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$2,911.24 Late Charges from 10/01/2006 to 02/28/2007 .............................................$197.05 Costs of suit and Title Search ......................................................................$900.00 ......................$15.00 ......................$ 57.88 $66,056.29 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. 8. 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 terris judgment in mortgage foreclosure in the sum of $66,056.29, together with interest at the rate of $20.72, 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. uv l?BI?McCAFFERTY & McK BY' 7EPH A. GOLDBECK, 7R., ESQUIRE A O EY FOR PLAINTIFF VERIFICATION I, Erin Kelly, 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 unworn falsification to authorities. Date: 2 ' 2 Erin Kelly, Sr. Fo closure Specialist AMERIQUESTMORTGAGE CORPORATION ExhibitA -- -.--N - 41P. --- -, -..- ALL that certain tract of land situate in the Township of Hopewell, Cuffiberland 'County, Pennsylvanla, bounded and described as follows: r BEGINNING at a point In a Township road at corner of lands now or formerly of Richard Gayer; thence in a southerly direction and by Ueda of the said Richard Oyer and also by lands nov or formerly of George Mon n, five hundred (500) feet to an iron'pin; theeepe in an Easterly direction by Iands now or formerly of J. Preston Thrush one hundred fifty (150) fact to an iron pin; thence by the OWN and in a Northerly direction five hu4red (500) feet to a point in the center of the aforesaid Township road; thence by the center of the aforesaid Totmehip road in a Westerly direction one hundred fifty (150) feet to the place of*BEGIMtING. CONTAINING 2 acres mare or less. SWECT TO:, a life estate interest in the above described real estate in the above mentioned Dolly Rohm,.ona of the Grantors herein. EEZRG the samw which Dolly Rohm, by her deed dated March S. 1976, and recorded in the Office of the Recorder of Deeds, in and for Cumberland County, Pennsylvania, i.n Dead Book "M", Volume 26, at Page 677, conveyed to Naomi Dianne Briggs and James H. Briggs, Jr., her husband, two of the Grantors herein. ?hi6it B 1 t AMCP.O. Box 11000 MORTGAGE SERVICES Santa Ana, CA 92711-1000 #BWNKZZS December 04, 2006 JOSEPH A ROHM IM) NMI ANNA M ROHM 57 TABOR RD NEWBURG, PA 17240-9350 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE AVISO: Este documento explica como los propietarios de casas pueden evitar perder sus hogares debido a demoras de pagos. Para infonnaci6n en espailol llame a su prestamista. STATEMENTS OF POLICY Loan Number: 0036002251 Property Address: 57 TABOR RD, NEWBURG PA, 17240 Original Lender: AMC Mortgage Services, Inc. Current Lender/Servicer: AMC Mortgage Services, Inc. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is as official notice that the mortgage on your home is is default, and the leader intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM gMMAP) may be able to help to save your home. This Nedce explains how the program works. To we 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 vow when yes meet with the Counseling Agars. Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869). p a w This Notice contains important legal information, H 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 Bad a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUZS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO """ a Also doing business as Delaware AMC Mortgage Services, Inc., in the states of Texas, Rhode Island, and New Hampshire. ARRIBA. PIIEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM"1L CUAL PIIEDE SALVAR SII CASA DE LA PERDIDA DEL DERECHO A REDI IIR SII HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FITTIIRE 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; s IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, s 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 -you meet %= nat4w m gaze of this meeting The names. addresses and teknhcne numbers of deli8mkd consumer er credit JI the My -ft n in which the n eo '"° ageades for roperty 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 immediatefi of your interions. APPLICATION FOR MORTGAGE ASS TANCE - Your mortgage is in a 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-fam meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER 71M 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 hands 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 ff 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. 6040~2-06 December 04, 2006 Loan Number: 0036002231 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 Mortsage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Briat it to t ? NATURE OF THE DEFAULT -The MORTGAGE debt by the above lender on your property located at: 57 TABOR RD, NEWBURG, PA 17240 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: 10101/06 thm 12/01106 at $724.31 per month Monthly Payments plus late charge or other fees: $2291.52 Total Amount to Care Default: $2291.52 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use U not applicable): N/A HOW TO CURE THE DEFAULT -You may care the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2291.52 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's chit certified check or monw order made payable and sent to AMC Mortgage Services 505 City Parkway West Spite #100 Orange, CA 92868 You can care any other default by taking the following acWn within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable) N/A IF YOU DO NOT CURE THE DEFAULT If you do not care 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 ntor ft#Wd ro e IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your can 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 oweed $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 defan_k within the THIRTY (30) DAY period, you will not be required to pal attomey's fern. OTHER LENDER REMEDIES - The lender may also sae you personally for the unpaid principal balance and all other sums den under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cared the default within the THIRTY (30) DAY period and foreclosure proceedings have began, yon still have the riseht to care the dchult and prevent the sale at any time up to one hour before the Sheriffs Sale. YOU may do so paving the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs coup-4-1 -rich A- 2doMlil other rea?eu meats under the mortg;g4, Caring your default in the manner set forth in this notice will restore your mortpp 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 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 care the default will increase the longer you wait. Yon may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: AMC Mortgage Services PO Box 11000 Santa Ana, CA 92711-1000 Phone Number 800-430-5262 Fax Number 714-347-5037 EFFECT OF SHERPTS SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged Property and your right to occupy it. If You continua to live in the property after the Sheriffs Sale, a lawsuit to remove you and your fumishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- Yon mayor R may not (CHECK ONE) 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: s 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. s TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. s 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) z TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, s TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER Z TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED If you need additional assistance or counseling you may also find a Housing Counseling Agency in your area by calling Toll-free (800) 5694287 or TDD (800) 877-8339. AMC Mortgage Services Cc: AMC Mortgage Services Attn: Collections Department Loan Number: 0036002251 Mailed by 1st Clam Mail and by Certified Man Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 1-888-511-2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17110 1-800-342-2397 MAM111CO-12-05 _ qQ 70 Pk. Ul d CIO ? r t'? r-? CO -Ti ty Deutsche Bank National Trust Company VS Joseph A. and Anna M. Rohm In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-696 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Joseph Goldbeck. Sheriff's Costs: Docketing $30.00 Poundage 2.52 Levy 15.00 Avertising 15.00 Mileage 18.24 Law Library .50 Prothonotary 1.00 Share of Bills 16.17 Surcharge 30.00 $ 128.43 ?, DO So Answers: R. Thomas Kline, Sheriff BY Ca" Real Estate $ geant $ S4D S a C91 * 14 14 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-696 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET- BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff (s) From JOSEPH A. ROHM AND ANNA M. ROHM (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 $66,304.93 L.L. $.50 Interest FROM 3/13/07 TO DATE OF SALE AT 12.9900% Atty's Comm % Due Prothy $1.00 Atty Paid $142.72 Other Costs Plaintiff Paid Date: MARCH 13, 2007 (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale # 105 On March 16, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Hopewell Township, Cumberland County, PA Known and numbered as 57 Tabor Road, Newburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 16, 2007 By: Real Es to Sergeant S t c_-. a 1J lu Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM (Mortgagor(s) and Record Owner(s)) 57 Tabor Road Newburg, PA 17240 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-696 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE, SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 57 Tabor Road Newburg, PA 17240 1.Name and address of Owner(s) or Reputed Owner(s): JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 2. Name and address of Defendant(s) in the judgment: JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ANNA M. ROHM 57 Tabor Road T, Newburg, PA 17240 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PENN LAUREL GIRL SCOUT COUNCIL 1600 Mt. Zion Road P.O. Box 20159 York, PA 17402 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street PO Box 15057 Harrisburg, PA 17101 PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street Earrisburg, PA 17101 5. 'g`ame and ad?l:e?s ut c?er. , pers.?tt ,?n? ,'- co?zi n u 011 the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 57 Tabor Road Newburg, PA 17240 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and c ect to t best of my personal knowledge or information and belief. I understand that false statements herein are made subject the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. IF r DATED: March 12, 2007 GOLDBECK cC F TY & McKEEVER BY: Joseph )P(. Gol ec Jr., Esq. Attorney fd7r Plaintiff I 07-696 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s; Tetra No. 07-696 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROHM, ANNA M. ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Your house at 57 Tabor Road, Newburg, PA 17240 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $66,304.93 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07-696 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-696 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: 717-243-9400 or. 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). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). 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 homeretentionggoldbecklaw.com. Call Judy 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 AMQ-1646. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 07-696 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s' , Term No. 07-696 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROHM, JOSEPH A. JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 Your house at 57 Tabor Road, Newburg, PA 17240 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $66,304.93 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS 07-696 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-696 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: 717-243-9400 or. 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). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). 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 Judy 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 AMQ-1646. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF HOPEWELL, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN A TOWNSHIP ROAD AT CORNER OF LANDS NOW' OR FORMERLY OF RICHARD GUYER; THENCE IN A SOUTHERLY DIRECTION AND BY LANDS OF THE SAID RICHARD GUYER AND ALSO BY LANDS NOW OR FORMERLY OF GEORGE MONN, FIVE HUNDRED (500) FEET TO AN IRON PIN; THENCE IN AN EASTERLY DIRECTION BY LANDS NOW OR FORMERLY OF J. PRESTON THRUSH ONE HUNDRED FIFTY (150) FEET TO AN IRON PIN; THENCE BY THE SAME AND IN A NORTHERLY DIRECTION (500) FEET TO A POINT IN THE. CENTER OF THE AFORESAID TOWNSHIP ROAD; THENCE BY THE CENTER OF THE AFORESAID TOWNSHIP ROAD IN A WESTERLY DIRECTION ONE HUNDRED FIFTY (150) FEET TO THE PLACE OF BEGINNING. CONTAINING 2 ACRES MORE OR LESS. TAX PARCEL NO: 11-06-0043-068 SHERIFF'S RETURN - REGULAR CASE NO: 2007-00696 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS ROHM JOSEPH A ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DnTJM .7nQL11DU A the DEFENDANT , at 1443:00 HOURS, on the 9th day of February , 2007 at 57 TABOR ROAD NEWBURG, PA 17240 by handing to ANNA ROHM, ADULT IN CHARGE 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: So Answers: Docketing Service 18.00 16 . 72 ? P Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 44.72 02/12/2007 Oq GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed a15, to By: before me this day Deputy Sheriff of A.D. CASE NO: 2007-00696 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS ROHM JOSEPH A ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE ROHM ANNA M the DEFENDANT , at 1443:00 HOURS, on the 9th day of February-, 2007 at 57 TABOR ROAD NEWBURG, PA 17240 by handing to ANNA ROHM 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 Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 6.00 .00 .00 10.00 R. Thomas Kline .00 16.00 02/12/2007 a 6.01 GOLDBECK MCCAFFERTY MCKEEVER By: day eputy Sheriff A. D. was served upon lb PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 IN THE COURT OF COMMON PLEAS of County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-696 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 03/13/2007 to Date of Sale at 12.9900% $66,304.93 (Costs to be added) GOLDBECK McCAFFE TY & BY: Michael T. McKeev r Attorney for Plaintiff ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF HOPEWELL, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN A TOWNSHIP ROAD AT CORNER OF LANDS NOW OR FORMERLY OF RICHARD GUYER; THENCE IN A SOUTHERLY DIRECTION AND BY LANDS OF THE SAID RICHARD GUYER AND ALSO BY LANDS NOW OR FORMERLY OF GEORGE MONK, FIVE HUNDRED (500) FEET TO AN IRON PIN; THENCE IN AN EASTERLY DIRECTION BY LANDS NOW OR FORMERLY OF J. PRESTON THRUSH ONE HUNDRED FIFTY (150) FEET TO AN IRON PIN; THENCE BY THE SAME AND IN A NORTHERLY DIRECTION (500) FEET TO A POINT IN THE CENTER OF THE AFORESAID TOWNSHIP ROAD; THENCE BY THE CENTER OF THE AFORESAID TOWNSHIP ROAD IN A WESTERLY DIRECTION ONE HUNDRED FIFTY (150) FEET TO THE PLACE OF BEGINNING. CONTAINING 2 ACRES MORE OR LESS. TAX PARCEL NO: 11-06-0043-068 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-696 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET- BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002 WITHOUT RECOURSE, Plaintiff (s) From JOSEPH A. ROHM AND ANNA M. ROHM (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 $66,304.93 L.L. Interest FROM 3/13/07 TO DATE OF SALE AT 12.9900% Atty's Comm % Due Prothy $2.00 Atty Paid $292.65 Plaintiff Paid Other Costs Date: FEBRUARY 28, 2008 (Seal) Curtis ong, Prot tary By: Deputy REQUESTING PARTY: Name MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: JOSEPH A. ROHM ANNA M. ROHM Debtor(s) DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE Movant V. JOSEPH A. ROHM ANNA M. ROHM CHARLES J. DeHART, III Esq. (Trustee) Respondents ORDER BK. NO. 1:07-bk-01003 MDF CHAPTER 13 Upon Consideration of the Certification of Default filed by the Moving Party in accordance with the Stipulation of the parties approved on October 02, 2007 it is ORDERED AND DECREED that: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1978 (The Code) 11 U.S.C. Section 362, is modified to allow DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, and its successor in title to proceed with the execution process through, among other remedies but not limited to Sheriff's Sale regarding the premises 57 Tabor Road Newburg,PA 17240 and a possessory action if necessary. By the C oxwt, Billtl r'up! ,' jtld#I` (JDK} Dated: January 28, 2008 This document is electronically signed and filed on the same date. Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM (Mortgagor(s) and Record Owner(s)) 57 Tabor Road Newburg, PA 17240 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-696 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 57 Tabor Road Newburg, PA 17240 1.Name and address of Owner(s) or Reputed Owner(s): JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 2. Name and address of Defendant(s) in the judgment: JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 IN THE COURT OF COMMON PLEAS of County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PENN LAUREL GIRL SCOUT COUNCIL 1600 Mt. Zion Road P.O. Box 20159 York, PA 17402 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street Harrisburg, PA 17101 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 57 Tabor Road Newburg, PA 17240 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the est of y personal knowlede or information and belief. I understand that false statements herein are made subject t e pen t e s of 18 Pa. C.S. Sect on 4904 relating to unsworn falsification to authorities. DATED: February 27, 2008 GOLDBECK M cCAF F RTY cKEEVER BY: Michael McKee er, Es Attorney for Pintiff ca 1_" sV -n r > Co ?.:. 07-696 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s Term No. 07-696 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROHM, JOSEPH A. JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 Your house at 57 Tabor Road, Newburg, PA 17240 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $66,304.93 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS Ir 07-696 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-696 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-696 L 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: 717-243-9400 or. 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). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). 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 homeretentionggoldbecklaw.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 AMQ-1646. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. C^'`• C rn .yy ?l N "'t7 O Wt 07-696 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s Term No. 07-696 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROHM, ANNA M. ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Your house at 57 Tabor Road, Newburg, PA 17240 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $66,304.93 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07-696 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7• You may also have other rights and defenses, or ways of getting your house 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-696 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 .1 07-696 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: 717-243-9400 or. 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). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). 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 AMQ-1646. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. n - ? n n cv nj N --a '' - co ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF HOPEWELL, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN A TOWNSHIP ROAD AT CORNER OF LANDS NOW OR FORMERLY OF RICHARD GUYER; THENCE IN A SOUTHERLY DIRECTION AND BY LANDS OF THE SAID RICHARD GUYER AND ALSO BY LANDS NOW OR FORMERLY OF GEORGE MONN, FIVE HUNDRED (500) FEET TO AN IRON PIN; THENCE IN AN EASTERLY DIRECTION BY LANDS NOW OR FORMERLY OF J. PRESTON THRUSH ONE HUNDRED FIFTY (150) FEET TO AN IRON PIN; THENCE BY THE SAME AND IN A NORTHERLY DIRECTION (500) FEET TO A POINT IN THE CENTER OF THE AFORESAID TOWNSHIP ROAD; THENCE BY THE CENTER OF THE AFORESAID TOWNSHIP ROAD IN A WESTERLY DIRECTION ONE HUNDRED FIFTY (150) FEET TO THE PLACE OF BEGINNING. CONTAINING 2 ACRES MORE OR LESS. TAX PARCEL NO: 11-06-0043-068 UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: JOSEPH A. ROHM ANNA M. ROHM Debtor(s) DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE Movant V. JOSEPH A. ROHM ANNA M. ROHM CHARLES J. DeHART, III Esq. (Trustee) Respondents ORDER BK. NO. 1:07-bk-01003 MDF CHAPTER 13 Upon Consideration of the Certification of Default filed by the Moving Party in accordance with the Stipulation of the parties approved on October 02, 2007 it is ORDERED AND DECREED that: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1978 (The Code) 11 U.S.C. Section 362, is modified to allow DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, and its successor in title to proceed with the execution process through, among other remedies but not limited to Sheriff's Sale regarding the premises 57 Tabor Road Newburg,PA 17240 and a possessory action if necessary. B the Comi, Dated: January 28, 2008 rup jud (JDK) This document is electronically signed and filed on the same date. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6342 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff Vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-696 JOSEPH A. ROHM and ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Defendant(s) PLAINTIFF'S PETITION TO AMEND JUDGMENT Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS- THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, petitions the Court to Amend its Judgment in mortgage foreclosure for the following reasons: 1. Plaintiffs Complaint in Mortgage Foreclosure was filed on February 01, 2007 as to the property located at 57 Tabor Road Newburg, PA 17240 ("Property"). 2. On March 13, 2007, judgment in mortgage foreclosure was entered in favor of Plaintiff and against Defendants in the amount of $66,304.93, based upon the demand in Plaintiffs Complaint. 3. Additional sums have been incurred or expended on Defendant's behalf since the complaint was filed. 4. On April 04, 2007 Defendants filed a petition in bankruptcy in the United States Bankruptcy Court for the Middle District of Pennsylvania (No. 07-01003-Middle) which stayed further prosecution of Plaintiffs action in mortgage foreclosure. 5. By order of United States Bankruptcy Court dated January 28, 2008 Plaintiff was granted relief from the automatic stay imposed by the Bankruptcy Code. 6. Since the filing of the Complaint, interest and late charges continue to accrue based on the rate set forth in the mortgage; and plaintiff has continued to pay taxes and hazard insurance premiums as required under the terms of the note and mortgage or under the terms of the mortgage contract in order to protect the interest of Defendants and Plaintiff. 7. Due to the increase in the amounts due and owing to Plaintiff, Plaintiffs judgment amount is not sufficient to satisfy the amounts due and owing on the mortgage and the mortgage lien on the Property. 8. A sheriff's sale is scheduled for June 11, 2008, and the amounts due and owing on the mortgage as of the sheriff's sale will be as follows: Principal Balance $58,129.39 Interest from 01/01/2007 thru 03/10/2008 at 12.9900% Per diem interest rate at $20.72 $10,896.26 Late Charges $707.04 Escrow $1,227.20 Sub-Total $70,959.89 Appraisal Fees $325.00 BPO Fees $95.00 Bankruptcy Fees $733.23 Bankruptcy Costs $150.00 Foreclosure Costs $3,794.59 Property Inspection $180.50 Sub-Total $76,238.21 Attorney's Fee at 5.0000% of principal balance $2,906.47 Costs of Suit and Title Search $900.00 TOTAL WHEREFORE, Plaintiff prays that the Petition be granted and Plaintiffs Judgment be amended to $80,044.68, plus interest and costs of the action. GOLD By: TY & McKEEVER Gary E. affertEsq. Phone: (215) 8215-- Fax: (215) 825-6402 Email: gmccafferty@goldbecklaw.com GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6302 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. JOSEPH A. ROHM and ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Defendant(s) VERIFICATION No. 07-696 Gary E. McCafferty, Esq., hereby states that he is the attorney for plaintiff and that all of the facts set forth within the attached Petition to Amend its Judgment are true and correct to the best of his knowledge, information and belief. The ifnc?rsigned understands that the foregoing statements are made subject to the penalties 18 P.S. Secdn 4904. Gary E. 1Vyc q Phone: (215) 825-63 Fax: (215) 825-6402 Email: gmccafferty@goldbecklaw.com IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6302 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002- 3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. JOSEPH A. ROHM and ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-696 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S PETITION TO AMEND JUDGMENT Plaintiff is entitled to the amounts due and owing pursuant to the terms of the mortgage and note at the time of the Sheriff's Sale of property involved. For reasons stated in the within motion, Plaintiff's judgment in mortgage foreclosure is insufficient to compensate Plaintiff for the amount due and owing under the mortgage. Specifically, interest charges, late charges and advances made by plaintiff to pay taxes, insurance, or to otherwise protect its mortgage lien and the interests of the Defendant, have all been accruing while Plaintiff's action in mortgage foreclosure was delayed. CONCLUSION For the reasons stated above and in the within petition, Plaintiff respectfully requests that the petition be granted and Plaintiffs judgment be amended to $80,044.68, plus interest and costs. submitted, GOLDBFPK Mc AEEERTY & McKEEVER By: Phone. 215) 825- 02 Fax:(21 5-640 Email: onccaf e o dbecklaw.com GOLDBECK McCAFFERTY & McI FEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6342 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002- 3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM and ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-696 CERTIFICATION OF SERVICE Jaclyn Jamieson is a legal assistant with the firm of GOLDBECK McCAFFERTY & McKEEVER and hereby certifies that a true and correct copy of Plaintiff's Petition to Amend Judgment was mailed by first class mail, postage prepaid to Defendant(s) JOSEPH A. ROHM and ANNA M. ROHM @ 57 Tabor Road Newburg, PA 17240 on April 17, 2008. GOLDBECK McCAFFERTY & McKEEVER By: G ldbeck cC fert& McKeever aclyn Jamieson Judgment Department Phone: (215) 825-6369 Fax: (215) 825-6378 Email: jjamieson@goldbecklaw.com GOLDBECK McCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION ATTORNEYS AT LAW SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 W W W.GO LDBECKLA W.COM April 17, 2008 PROTHONOTARY OF CUMBERLAND COUNTY Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 RE: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE vs. JOSEPH A. ROHM and ANNA M. ROHM Docket Number: 07-696 Our file Number: AMQ-1646 To the Prothonotary: Kindly file Plaintiff's Petition to Amend Judgment the same of record with the Court and return a time-stamped copy in the self-addressed stamped envelope enclosed. Very truly yours, Goldbeck McCafferty & McKeever Jaclyn Jamieson Judgment Department Phone: (215) 825-6369 Fax: (215) 825-6378 Email: jjamieson@goldbecklaw.com cc: JOSEPH A. ROHM ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 C ? p.,.,:9 ... 1...'? •?rtt ??. r-.. .? i?' tt?? _ -1, ? ? a ( ? , !"•.?' ?. ' ? rt , t. ? Cif 6 ? 4 ? e,? cy=: ; :7 . APR 2 4 2008? GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6342 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002- 3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM and ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-696 RULE AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested in Plaintiffs Motion to Reassess Damages should not be granted. 3 Rule returnable the ?3?ay of rAT Date: q 06 1 4'• . J. • S tjr , Y' r ono C? :9 Wv R 8dv goon 3HI J01 ` Y GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 500 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6302 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff No. 07-696 JOSEPH A. ROHM and ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Defendant(s) CERTIFICATION OF SERVICE OF RULE RETURNABLE Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiffs Petition for Reassessment of Damages and Rule Returnable Date of May 23, 2008 @ 10:00 a.m. was mailed by first class mail, postage prepaid to Defendant(s) JOSEPH A. ROHM & ANNA M. ROHM @ 57 Tabor Road, Newburg, PA V1 240 on May 7, 2008. GOLKEENER By: Ga E. M afferty, E 215- 5- 42 215-82 42 (fax) Email: mmccaffertv(c? iz dbe klaw.com Sworn and sub c ed to me t 7 d jf 44ay, 2008 OMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL BARBARA L. HAND, NoWry Public City of Philadelphia, Phila. Courity My Commission Expires June 19, 2010 GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6342 Attorney for Plaintiff ",APR $ 4 2008pi- DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002- 3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM and ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Defendant(s) RULE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-696 AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested in Plaintiffs Motion to Reassess Damages should not be granted. _ 3. Rule returnable the a3?ay of ,lam` 10: 60 C' ICI.4' Date: 1 v o J. TRUE COPY RIOT ?'??„? ±R?? ?o Testimony wWW, i hors unta t rn Fund 14 t0 wtl of said Coo of Cafgsw. ?a Oro nn? ?" C7 cn -< IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST a ?r MORTGAGE SECURITIES INC., SERIES 2002- 3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM and ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Defendant(s) ORDER CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-696 AND NOW, this 001 day of Ix rv?- , 2008, upon consideration of the Petition of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE to Amend its Judgment, it is, ORDERED: That the motion is granted and Plaintiffs judgment is hereby amended to $80,044.68, plus interest at the rate set forth in the note and m and costs of this action through and including the Sheriff's Sale of the Property o ayment o the mortgage loan in full. B J. 9 stn'bution list: ?ary E. McCafferty, Esquire, Suite 5000 - Mellon Independence Center, Philadelphia, PA 19106-1532 SEPH A. ROHM, 57 Tabor Road Newburg, PA 17240 ANNA M. ROHM, 57 Tabor Road Newburg, PA 17240 701 Market Street, ;0 VNR a yin i ? r'I-?? 00 d Z dv14 So I GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 AMQ-1646 CF: 02/05/2007 SD: 09/03/2008 $80,044.68 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-696 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: bQ Personal Service by the Sheriffs Office/ owo ed"A-(copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Officelcompetent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff 0 ?o :71 : 400, N O ryN p p p a 13 Erbil G IL Q 1 UL I Q J U _ N V R z m C U U (? $ DDOO _ ,3 O = O U. O ' ? 1 W 7 n z N co O a19 J a a 0=3 " J M m g? 3 ? p ti "'? Q Q ?? Z 0 0 ? ?i?N? x U Na a x U a 3 L ? a a _ 000 ???o Z U 1 m wzm_ O O ` . fi o 9 Q 3? i .? xz uJ C? i v . ara? S ) Vac U amS ll n Q S Inz a 8 loo Z c ?d x oW n l tgi uo w W2 W r b m W .? e p C-4 cM Ld CO 1? a0 IF d v N a a S N m 0 m N a C C E V d Q Q x Q W O w Vlf F +. Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc., Series 2002-3, Asset Backed Pass-through Certificates, Under the Pooling and Servicing Agreement Dated as of September 1, 2002, without Recourse vs Joseph A. Rohm and Anna M. Rohm In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-696 Civil Term (90-106) Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 02, 2008 at 1425 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Joseph A. Rohm and Anna M. Rohm by making known unto Anna Rohm personally and adult in charge for Joseph Rohm at 57 Tabor Road, Newburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Steve Bender, Deputy Sheriff; who being duly sworn according to law, states that on April 02, 2008 at 1425 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and description, in the' above entitled action, upon the property of Joseph A. Rohm and Anna M. Rohm located at 57 Tabor Road, Newburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff:, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner. The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Joseph A. Rohm and Anna. M. Rohm by regular mail to their last known address of 57 Tabor Road, Newburg, PA 17240. This letter was mailed under the date of April 17, 2008 and never returned to the Sheriffs Office. So Answers: R. Thomas Kline, Sheriff BY Real Estate eant • ' GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL, ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-696 AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 57 Tabor Road Newburg, PA 17240 1.Name and address of Owner(s) or Reputed Owner(s): JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 2. Name and address of Defendant(s) in the judgment: JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 PENN LAUREL GIRL SCOUT COUNCIL 1600 Mt. Zion Road P.O. Box 20159 York, PA 17402 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street Harrisburg, PA 17101 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 57 Tabor Road Newburg, PA 17240 (attach separate sheet if more space is needed) 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. Section 4904 relating to unworn falsification to authorities. DATED: June 17, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff C) ' "'cam 0 oc -n -3r U _ i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which AMERIOUEST MTG SERV INC TR is the grantee the same having been sold to said grantee on the 3RD day of SEPT A.D., 2008, under and by virtue of a writ Execution issued on the 28TH day of FEB, A.D., 2008, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 696, at the suit of DEUTSCH BANK NATIONAL TR CO against JOSEPH A ROHM & ANNA M is duly recorded as Instrument Number 200831967. IN TESTIMONY WHEREOF, I have her unto set my hand and seal of said office this p? day of I' Recorder of Deeds INW4ay o1JwL M0 Deutsche Bank National Trust Company, In the Court of Common Pleas of as Trustee of Ameriquest Mortgage Cumberland County, Pennsylvania Securities Inc., Series 2002-3, Asset-Backed Writ No. 2007-696 Civil Term Pass-through Certificates, Under the Pooling and Servicing Agreement Dated as of September 1, 2002, without Recourse vs Joseph A. Rohm and Anna M. Rohm Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 02, 2008 at 1425 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Joseph A. Rohm and Anna M. Rohm by making known unto Anna Rohm personally and adult in charge for Joseph Rohm at 57 Tabor Road, Newburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 02, 2008 at 1425 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and description, in the above entitled action, upon the property of Joseph A. Rohm and Anna M. Rohm located at 57 Tabor Road, Newburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Joseph A. Rohm and Anna M. Rohm by regular mail to their last known address of 57 Tabor Road, Newburg, PA 17240. This letter was mailed under the date of April 17, 2008 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 3, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of U.S. Bank National Association, as Trustee, In Trust for the Registered Holders of Ameriquest Mortgage Securities, Inc., Asset-Backed Pass-Through Certificates, Series 2002-3. It being the highest bid and best price received for the same, U.S. Bank National Association, as Trustee, In Trust for the Registered Holders of Ameriquest Mortgage Securities, Inc., Asset-Backed Pass-Through Certificates, Series 2002-3, of 505 City Parkway West, Suite 100, Orange, CA 92868, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1026.66. Sheriff s Costs: Docketing $30.00 Poundage 20.13 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Prothonotary 2.00 Mileage 37.00 Levy 15.00 Surcharge 30.00 Post Pone Sale 20.00 Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed 355.00 350.30 14.73 25.00 39.50 $ 1026.66 ? ??,?0 8 So Answers: R. Thomas Kline, Sheriff BY Real Estate rgeant Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. JOSEPH A. ROHM ANNA M. ROHM (Mortgagor(s) and Record Owner(s)) 57 Tabor Road Newburg, PA 17240 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-696 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 57 Tabor Road Newburg, PA 17240 1.Name and address of Owner(s) or Reputed Owner(s): JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 2. Name and address of Defendant(s) in the judgment: JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 IN THE COURT OF COMMON PLEAS of County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PENN LAUREL GIRL SCOUT COUNCIL 1600 Mt. Zion Road P.O. Box 20159 York, PA 17402 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street Harrisburg, PA 17101 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 57 Tabor Road Newburg, PA 17240 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the est of y personal knowledge or information and belief. I understand that false statements herein are made subject t? a pen ties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. A DATED: February 27, 2008 GOLDBECK MCCAFF RTY BY: Michael T. McKee er, EE Attorney for Plaintiff 07-69.6 GOLDBECK MCCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. JOSEPH A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Defendant(s Term No. 07-696 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROHM, JOSEPH A. JOSEPH A. ROHM 57 Tabor Road Newburg, PA 17240 Your house at 57 Tabor Road, Newburg, PA 17240 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm. 2nd FL Courthouse to enforce the court judgment of $66,304.93 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07-696 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-696 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-696 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: 717-243-9400 or . 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). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). 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(a?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 AMQ-1646. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 07-696 GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. JOSEPH. A. ROHM ANNA M. ROHM Mortgagor(s) and Record Owner(s) 57 Tabor Road Newburg, PA 17240 Term No. 07-696 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROHM, ANNA M. ANNA M. ROHM 57 Tabor Road Newburg, PA 17240 Your house at 57 Tabor Road, Newburg, PA 17240 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $66,304.93 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS 07=696 YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET-BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and ' 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-696 717-243-9440 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-696 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: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.g-o_v for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). 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(c?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 AMQ-1646. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF HOPEWELL, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN A TOWNSHIP ROAD AT CORNER OF LANDS NOW OR FORMERLY OF RICHARD GUYER; THENCE IN A SOUTHERLY DIRECTION AND BY LANDS OF THE SAID RICHARD GUYER AND ALSO BY LANDS NOW OR FORMERLY OF GEORGE MONN, FIVE HUNDRED (500) FEET TO AN IRON PIN; THENCE IN AN EASTERLY DIRECTION BY LANDS NOW OR FORMERLY OF J. PRESTON THRUSH ONE HUNDRED FIFTY (150) FEET TO AN IRON PIN; THENCE BY THE SAME AND IN A NORTHERLY DIRECTION (500) FEET TO A POINT IN THE CENTER OF THE AFORESAID TOWNSHIP ROAD; THENCE BY THE CENTER OF THE AFORESAID TOWNSHIP ROAD IN A WESTERLY DIRECTION ONE HUNDRED FIFTY (150) FEET TO THE PLACE OF BEGINNING. CONTAINING 2 ACRES MORE OR LESS. TAX PARCEL NO: 11-06-0043-068 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-696 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF AMERIQUEST MORTGAGE SECURITIES INC., SERIES 2002-3, ASSET- BACKED PASS-THROUGH CERTIFICATES, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2002 WITHOUT RECOURSE, Plaintiff (s) From JOSEPH A. ROHM AND ANNA M. ROHM (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 $66,304.93 L.L. Interest FROM 3/13/07 TO DATE OF SALE AT 12.9900% Atty's Comm % Due Prothy $2.00 Atty Paid $292.65 Other Costs Plaintiff Paid Date: FEBRUARY 28, 2008 (Seal) Curtis R. ong, Pro By: REQUESTING PARTY: Name MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Deputy Supreme Court ID No. 56129 Real Estate Sale # 71 On March 11 2008 the Sheriff levied upon the defendant's interest in the real property situated in Hopewell Township, Cumberland County, PA Known and numbered as 57 Tabor Road, Newburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 11, 2008 Tt?3 Real Estate ergeant Is -.8 v q - bVA 800' 'dd `A1NI " PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: May 2, May 9, and May 16, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Visa Marie Coyne, E or SWORN TO AND SUBSCRIBED before me this - - 16 day of May, 2008 Notary / NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28. 2010 MAi. 32WAft 2"S >ii61. 71 Writ No. 2007-696 Civil Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc. Series 2002-3, Asset Backed Pass- Through Certificates, Under the Pooling and Servicing Agreement Dated as of September 1, 2002, without recourse vs. Joseph A. Rohm and Anna M. Rohm Atty.: Michael McKeever ALL THAT CERTAIN tract of land situate in the TownW* at , CumaherLnd County, PennWhania, bounded and deverFmA as Mows: BrAHNiNIiNG at a point in a town- ship road at corner of lands now or formerly of Richard Guyer; thence in a southerly direction and by lands of the said Richard Guyer and also by lands now or formerly of George Monn, five hundred (500) feet to an iron pin; thence in an easterly direc- tion by lands now or formerly of J. Preston Thrush one hundred fifty (150) feet to an iron pin; thence by the same and in a northerly direction (500) feet to a point in the center of the aforesaid township road; thence by the center of the aforesaid town- ship road in a westerly direction one hundred fifty (150) feet to the place of beginning. CONTAINING 2 acres more or less. TAX PARCEL NO: 11-06-0043- 068. he Patriot-News Co. • 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ?hePatriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harri:;burg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The flatriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/23/08 04/30/08 05/07/08 Sworn to an scribed before me this 27 day of May, 2008 A.D. CX?- X?e?AOI Notary Pu li COMMONWEALTH OF PENNSYLVANIA Notarial Seal Chyrie L. Sheppard, Notary Public City Of Harrisburg, Dauphin County My Commission Expires May 29, 2010 Member, Pennsylvania Association of Notaries Real Estate Sale #71 Writ No. 2007-896 Civil Term Deutsche Bards National Trust Company, as Trustee of -. vnerkluest Mortgage Securities Inc. Series 2002,3, Asset Backed Pass-Through Certificates, Under the Pooling and Servicing Agreenwd Dated as of September 1, 2002, without recourse vs Joseph A. Rohm and Anna M. Rohm Attorney: Michael McKeever DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF HOPEWELL, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN A TOWNSHIP ROAD AT CORNER OF LANDS NOW OR FORMERLY OF RICHARD GUYER; THENCE IN A SOUTHERLY DIRECTION AND BY LANDS OF THE SAID RICHARD GUYER AND ALSO BY LANDS NOW OR FORMERLY OF GEORGE MONN, FIVE HUNDRED (500) FEET TO AN IRON PIN; THENCE IN AN EASTERLY DIRECTION BY LANDS NOW OR FORMERLY OF J. PRESTON THRUSH ONE HUNDRED FIFTY (150) FEET TO AN IRON PIN; THENCE BY THE SAME AND IN A NORTHERLY DIRECTION (500) FEET TO A POINT IN THE CENTER OF THE AFORESAID TOWNSHIP ROAD; THENCE BY THE COMM OF THE AFORESAID TOWNSHIP ROAD IN A WESTERLY DIRECTION ONE HUNDRED FIFTY (150) FEET TO THE PLACE OF BEGINNING. CONTAINING 2 ACRES MORE OR LESS. TAX PARCEL NO: 11-06W43-068 Assignment of Bid NO. 07-696 - ROHM 57 Tabor Road Newburg, PA 17240 I, Michael T. McKeever, Esquire, as attorney for the successful bidder, hereby assign my bid at the Sheriff Sale dated September 03, 2008 to: U.S. Bank National Association, As Trustee, In Trust for the Registered Holders of Ameriquest Mortgage Securities, Inc., Asset-Backed Pass-Through Certificates, Series 2002-3 505 City Parkway West Suite 100 Orange, CA 92868 GOLDBECK MCCAFFERTY & MCKEEVER Date: September 15, 2008 V1 % 100 MICHAEL T. MCKEEVER